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Legal Update

Petrobras Includes a Compliance Due Diligence Procedure in its Procurement Process

26 August 2015
Tauil & Chequer Legal Update

A notice was published on August 25, 2015, on the Petronect Portal, the Suppliers Relationship Portal of the Petrobras Group, informing about the creation of a new criterion for the assessment of suppliers as a result of the implementation of the Petrobras Anti-Corruption Program (PCPP).

The PCPP, which was created by Petrobras in December 2014, seeks to enhance the prevention, detection and correction of frauds and corruption by means of an integrated management and corporate governance actions and controls within Petrobras.

The compliance due diligence procedure (DDI in the Portuguese acronym) was created as part of the PCPP, and has the purpose of evaluating Petrobras’s suppliers using a compliance criterion.  This new procedure is also in accordance with the requirements imposed by Decree 8.420/2015 and shows Petrobras’s willingness to establish a compliance program that meets legal standards.

Therefore, companies initiating their initial registration with Petrobras’s list of suppliers (CRCC) will answer the compliance questionnaire containing information on to their reputation, integrity and anti-corruption practices.

For companies already registered with the CRCC the compliance questionnaire will be requested at the time of renewal of the registration with Petrobras’s list of suppliers (CRCC) and their Simplified Registration Statement (DRS).  Notwithstanding, the performance of a compliance due diligence process may be required at any time, at Petrobras’s sole discretion.

To fulfill the new requirements established by Petrobras, suppliers will need to have effective compliance programs.

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