Subject: FCPA
From: [email-masked]
To: [email-masked]
Cc: [email-masked]
Date: Mon, 1 Oct 2001 09:48:08 -0700 (PDT)

Short-form FCPA clause as follows - 

 	Both parties agree that they will not, and shall procure that its Affiliates and their respective employees will not, make, cause to be made, or promise or offer to make, in connection with this Agreement, any payment, loan, gift or transfer of anything of value, directly or indirectly: (i) to or for the use or benefit of any government official or government employee (including employees of government-owned entities or corporations); or (ii) to any political party, official of a political party or candidate; or (iii) to an intermediary for payment to any of the foregoing, in order to obtain or retain business or to secure any improper advantage.

I think the full one-page clause plus one-page schedule is a bit much for a confidentiality agreement but the above might be appropriate.
I will be around for a little while this evening so any other problems give me a call.
Thanks
Mike
__________________________________
Michael Slade
Enron Europe Legal Department
Tel: +44 207 783 7433
Fax: +44 207 783 8667