Compliance

Processes and activities governed by integrity

Integrity that governs our processes and activities

Our Compliance aims for alignment with a set of rules, standards, ethical and legal procedures that guide the behavior of the workforce and management, with a view to preventing, detecting and correcting unlawful acts that may be performed against the company.

Good Corporate Governance and Compliance practices are a pillar that sustains our businesses.

The main documents that set out Compliance parameters are: Program for the Prevention of Corruption (PPC-TBG), the Code of Ethics, Compliance Policy, Petrobras System Conduct Guide and the Guide to Receiving and Offering gifts, giveaways, hospitality and sponsorship contributions. These documents deal with, among other things, issues such as conflicts of interest, nepotism and money laundering.

Compliance Clause

Our contractual drafts include a compliance clause, which provides for compliance obligations and commitments and aims to establish a business relationship with our suppliers based on ethics, integrity and transparency.

Among the established commitments is compliance with the prevailing legislation to prevent corruption and money laundering.

Integrity Due Diligence (IDD)

One of the actions under the TBG Program for the Prevention of Corruption (PPC-TBG) is Integrity Due Diligence (IDD), which aims to increase the security of contracts for goods and services and mitigate any risks in the relationship with our suppliers, by providing a basis for assessment under the Integrity criterion.

To meet that criterion, companies need to provide information about their organizational and business structure, relationship with public agencies, integrity track record, relations with third parties and integrity program. This information supports the IDD procedure, the result of which is the assigning of a Degree of Integrity Risk (DIR).

*********

Contractual Regulations

State-Owned Companies Law

The State-Owned Companies Law (nº 13,303/16), enacted on June 30, 2016 and regulated by Decree nº 8,945/2016, of December 27, 2016, deals with the legal status of publicly listed companies, mixed-capital companies and their subsidiaries , within the federal, state, Federal District and municipal spheres. It is considered to be a regulatory milestone for the operations of these companies, with the setting out of procedures and responsibilities.

Regulating of TBG Tendering and Contracts (RTTC)

To regulate the general contractual standards and meet the requirements of Article 40 of Law nº 13,303/16, the TBG Regulating of Tendering and Contracts was drawn up, supplementing the provisions of the law.

The document, approved by the TBG Supervisory Board in April 2018 and published in the government’s Official Gazette on June 25th of that same year, presents new contractual formats and the steps to be followed in tendering.

Regulating of TBG Tendering and Contracts (RTTC)

Terms for the Supplying of Material (TSM)

The Terms for the Supply of Material regulate the provision of Goods and Services in relation to the TBG. They seek to improve the company's relationship with its supplier market. The document has been revised, as its application will accompany the implementation of the State-Owned Companies Law and the RTTC.

The principal innovation of the TBG TSM 2018 was motivated by Article 76 of Law nº 13,303/16, which provides for supplier liability for damages caused directly to the TBG or to third parties, regardless of intent or fault. Due to the significant change introduced by the law, certain items related to the obligations and responsibilities of suppliers were modified.

Terms for the Supplying of Material (TSM 2018)

Means of announcing Tendering

TBG's Calls to Tender are published in the government’s Official Gazette (DOU) and at the Petronect Electronic Portal (www.petronect.com.br), thus enabling any supplier to participate in the tendering process.

Integrity Due Diligence

INTEGRITY DUE DILIGENCE - Evaluation of information about reputation, trustworthiness and anti-corruption practices, as filled out in the Integrity Due Diligence (DDI) questionnaire.

 

Reporting Channel:

Click here or call (0800) 601 6925 if you wish to report illicit conduct.

Toll free telephone service, available 24/7.

 

Ethics

Policies and Guidelines

Learn more about the TBG Corruption Prevention Program Manual.

See also our Guide to Receiving and Offering gifts, giveaways and hospitality and sponsorship contributions.