In 2021, we applied 147 disciplinary measures to employees of different hierarchical levels, 11 contract terminations, 53 suspensions, and 83 written warnings. The cases refer to misconduct such as non-compliance or omission of internal regulations, non-compliance or omission of contracting/contract management procedures, insubordination, and others.
Our internal procedures revealed no new cases of corruption as defined by article 317 of the Penal Code, involving employees in 2021.
It should be noted that pre-procedural investigations of facts that occurred prior to 2019 are ongoing, within the scope of the competent external bodies. On the other hand, in the legal realm, we received formal confirmation regarding four unappealable final court decisions, regarding charges made between 2014 and 2021, regarding Operation Car Wash. In the criminal realm, in addition to the cases reported in the Operation Car Wash item, mentioned later on, our Legal Department follows five lawsuits arising from the Dutch company SBM Offshore, two of which are split-offs and another six criminal proceedings involving corruption crimes. However, it is not possible to speak technically about confirmed cases, since there was no final judgment of these cases.
We also had, within the scope of Administrative Accountability Processes (PAR), 37 investigations that resulted in the liability of 38 legal entities for the practice of harmful acts in Law 12.846/2013 - Corporate Anticorruption Law.