Business Ethics and Fighting Corruption

Integrity due diligence

We perform Integrity Due Diligence (DDI) of counterparties to know and assess the integrity risks inherent in our relationship with suppliers of goods and services; customers in the sale of oil products and oil; institutions in sponsorship projects and agreements for Communication and Social Responsibility functions; and companies interested in the asset divestment processes and/or equity interests, or strategic and operational partnerships.

The DDI result is expressed by the Integrity Risk Level (GRI) in high, medium and low categories, and is considered by managers in our decision-making process. In 2021, the Compliance team assigned 3,491 GRIs to our suppliers.

Integrity Background Check

Another integrity mechanism we use is the Integrity Background Check (BCI). The BCI seeks to support managers and senior management in making decisions regarding the nomination of candidates for key positions, through the analysis of legal requirements and compliance with Petrobras' Code of Ethical Conduct and our Policy for Nomination of Managers. In 2021, we conducted 2,853 BCI assessments.

Our risk management directs our integrity actions and strengthens our internal controls and governance.

Annually, we prepare and review an integrity risk matrix which maps our business processes that are most exposed to these risks. In 2021, 253 processes (100%) were reassessed based on risk factors related to fraud and corruption.

In order to avoid deviations in the use of resources related to the projects we sponsor, project proposals go through various analysis processes - technical, documentary, budgetary - prior to the start of contracting, ensuring that governance and compliance procedures are followed, and seeking to prevent possible conflicts of interest.

Within the scope of our integrity system, we seek to maintain the reduction of the indicator - Number of Inventory Investigations (NAE) - related to issues of conflict of interest, nepotism, irregularities in hiring processes, bribery/kickback, among others, as well as to investigate administrative responsibility for the practice of harmful acts committed by legal entities against Petrobras, considering Law No. 12,846/2013 - Administrative Liability Proceedings (PAR).

In 2021, we achieved a 22% reduction in NAE, which meant an accumulated reduction of 55% compared to December 2019.

The reduction of the NAE and PAR, together with other measures, contributes to the effectiveness of our integrity system, as it demonstrates our commitment to quickly investigate reported situations to identify possible irregularities, implement corrective actions, and improve of processes.

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.