Sustainability Report
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Acting with integrity

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Business integrity

 

The best corporate governance and compliance practices constitute a pillar for our business. Our activity is guided by ethics, integrity, and transparency. Additionally, considering our operations in increasingly competitive markets, it is important that our governance model ensures a balance between efficiency and control to guarantee us agile and safe operations at the same time, in addition to encouraging the adoption of practices related to environmental, social and governance (ESG) with our stakeholders.

 

In order to act ethically and with integrity, we consider four relevant topics:

• Consolidation of the culture of integrity in the organizational culture;

• Commitment to transparency;

•Governance focused on efficiency and control;

•Promotion of the ESG theme among our stakeholders.

INTEGRITY SYSTEM

 

 

Ethics in adopting artificial intelligence and new technologies

We recognize that artificial intelligence (AI) has the potential to transform several aspects of our operations, but we are committed to ensuring that this transformation occurs in an ethical, transparent, and responsible manner. Before implementing any new technology, we conduct a thorough analysis of its potential impacts, considering not only the operational benefits but also the associated ethical and social risks. Additionally, we are discussing internal guidelines and policies to govern the use of AI, ensuring it is used in a way that respects human rights, data privacy and equity. Thus, we ensure that our adoption of new technologies is always aligned with our ethical values and our commitment to sustainability.

Training and communication

The disclosure of policies, rules and procedures related to ethics and integrity is carried out to all our stakeholders through campaigns and internal and external actions in the various communication channels. These actions are planned based on our compliance risk analysis and are combined with specific training  actions.

 

Of our total employees, 97.6%1 were trained in preventing and combating discrimination, moral harassment,  and sexual violence, with 39,235 employees participating.

 

1 When considering the target audience for the training (which includes requested professionals from other corporate holdings and external entities), excluding employees on long-term leave and those seconded to other companies within the Petrobras System and external entities, the achievement rate reached was 99.4%

Compliance Risk Management

In 2023, all company processes were reevaluated2 based on risk factors related to fraud and corruption.

2 Considering the configuration of process standards in the company's hierarchy, all level 2 processes have been reassessed.

 

Our integrity system is subject to the risk that managers, employees, contractors, or anyone doing business with us may engage in fraudulent activities, corruption, or bribery, circumvent, or override its internal controls and procedures, or misappropriate or manipulate its assets for their personal benefit or that of a third party, against our interests. In this sense, one of the objectives of the integrity system is the prevention and treatment of these risks.

 

Integrity mechanisms in the value chain

We conduct Integrity Due Diligence (DDI) of counterparties in order 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 related to Communication and Social Responsibility;  parties to cooperation agreements and other types of partnerships; shipowners and brokers; and companies interested in asset divestment processes and/or in equity interests, 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 2023, the Compliance team assigned 2,370 GRIs to our suppliers. Reinforcing our commitment to the topic of human rights, in October 2023, the topics Human Rights and Personal Data Protection were included in the Integrity Due Diligence Questionnaire. The information collected on these topics will be used for preventive action within our supply chain

 

The Integrity Background Check (BCI) is an integrity mechanism that aims to support managers and senior management in making decisions regarding the appointment of candidates for key positions, through the analysis of legal requirements and compliance with our Bylaws and our Director Appointment Policy. In 2023, we carried out 5,342 Integrity Background Check assessments.

Investigations

Reports related to compliance incidents and workplace and sexual violence are investigated by Corporate Integrity, an area dedicated to dealing with these issues in the company. In 2023, we maintained the  reduction in the average time of ongoing investigations related to these topics, although there was a 19% increase in the logging of investigation protocols, resulting from a greater volume of received cases compared to previous years.

 

The reduction in the average time of ongoing investigations demonstrates our commitment to quickly investigating reported situations and, together with other measures, contributes to the effectiveness of our integrity system, to the identification of possible irregularities and to the implementation of corrective actions and process improvement

 

t is worth highlighting the creation of a new executive management department to conduct the disciplinary accountability process, including the administrative accountability process provided for in the AntiCorruption Law, segregating the investigation activity from the accountability activity.

Sanctions for individual and corporate entities

In 2023, we applied 72 disciplinary measures to employees at different hierarchical levels at Petrobras parent company, including 5 contract terminations with cause, 30 suspensions and 37 written warnings. The cases refer to misconduct such as non-compliance or omission of internal regulations, negligence in the performance of functions, insubordination, among others.

 

 

Within the scope of the Administrative Accountability Procedures, 41 were cloncluded, of which 34 resulted in the holding of 41 legal entities responsible for the practice of harmful acts in accordance with the Corporate Anti-Corruption Law.

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