Training

Launchedin2021withtheaimofbringingtheethicsandintegritytopictotheoffshoresegment,thePetrobras Journey for Integrity expanded its actions in 2022. The pilot project was carried out at the P-74 unit and expanded to another 12 platforms belonging to the Búzios, UN-ES and UN-BS assets. In addition, some refineries and thermoelectric plants received visits from the Compliance area. In2022, Distance Learning for Counterparties was launched, which is another trainingoption for our suppliers. This Distance Learning addresses themes from the Petrobras Ethical Conduct Guide for Suppliers , using case studies as a learning resource. The training was launched in March 2022. The first wave targeted around 70 suppliers,selected based on criteriasuch as the Integrity Risk Level(GRI) and the value oftheir active contract with Petrobras.

Petrobras Dialogues

In December 2022, the annual integrity event “Petrobras Dialogues” took place. In its 8th edition, the event, aimed exclusively at the internal public, had the purpose of recognizing and celebrating the company's Journey for Integrity. The action was aimed at strengthening the relationship of trust between employees in the integrity system, as well as awakening a sense of belonging and highlighting the importance of each person’s role along this journey.

100% Transparency Movement

As participants in the UN Global Compact, we have participated, since 2021, in the “100% Transparency Movement,” an initiative of the Global Compact Brazil Network, which seeks to contribute to the achievement of the Sustainable Development Goals of the 2030 Agenda. The companies participating in this initiative undertake to adopt measures that go beyond their legal obligations, such as strengthening mechanisms of transparency and integrity.

In all, the movement proposes five goals for members to achieve in stages by 2030:

• 100% transparency in dealings with government officials;

• 100% integrity in senior management compensation;

• 100% of the high-risk value chain trained on integrity;

• 100% transparent compliance and governance structures; and

• 100% transparent whistleblowing channels.

International compliance cooperation

After improving our control mechanisms in recent years, we are intensifying cooperation with bodies such as the Organization for Economic Cooperation and Development (OECD), Transparency International and the World Economic Forum, with the aim of improving the business environment in organizations and in the world.

Compliance risk management

Our risk management directs our integrity actions and strengthens our internal controls and governance. Our Corporate Risk Management Policy defines that this management is part of our commitment to act ethically and in compliance with the legal and regulatory requirements established in the jurisdictions where we operate.

We define compliance risks as those related to our integrity system, covering compliance with legislation and regulations applicable to our business and operations, compliance with internal policies and procedures, and compliance with values, ethical principles and guidelines for conduct. Each job we carry out is part of a macroprocess, that is, a group of activities focused on one of the company’s objectives. The Petrobras Value Chain is the integration between the macroprocesses of all areas, whether business macroprocesses, management macroprocesses and corporate services. The macroprocesses unfold into processes that are transversal to the company’s operations. Annually, we prepare and review the compliance risk matrix for the most exposed processes.

In 2022, 258 processes (100%) of the company were reassessed based on risk factors related to fraud and corruption.

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.

We continuously monitor our business processes to identify potential compliance deviations. Monitoring and control efforts are based on our integrity risk assessment. Whenever we identify an incident, we carry out a cause analysis to improve the business process and/or its respective controls, alerting those responsible for the failure to execute. If there are any sign of fraud, additional measures are taken. Our monitoring is continuously evaluated in relation to the effectiveness of the results obtained, in order to allow the development of new types of monitoring and implement the necessary changes in processes, controls, information technology systems, training, among others. Tools for mitigating risks such as fraud, corruption and breaches of ethics in general, among which we highlight the monitoring of compliance risks and the operational work of the Internal Audit area, as well as those within the scope of SOx certification These are carried out in an integrated manner with the Executive Compliance Management through the execution of control tests. Internal Auditing, certified by the Institute of Internal Auditors Brazil, provides officers, executive managers and unit managers with operational audit reports, in addition to quarterly reports of their results to the Statutory Audit Committee, the Executive Board and the Board of Directors, so that the executives can monitor the implementation of the improvements.

Internal controls and technology usage

The company updated its business management system, bringing a set of new technological solutions to conduct its corporate and business processes.

We were able to automate around 34% of our internal controls, including those aimed at preventing and detecting potential occurrences of fraud and corruption.

This level of automation allows us to reduce efforts in manual and repetitive tasks and reallocate our workforce to activities with greater added value, in addition to increasing the reliability and safety of processes.

Integrity mechanisms in the value chain Integrity due diligence

We perform 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 agreements; shipowners and brokers; and companies interested in asset divestment processes and/or in corporate holdings, strategic and operational partnerships.

Among the verifications carried out during the DDI procedure are the identification of final beneficiaries of the legal entity, the use of intermediaries in business with Petrobras, the existence and application of integrity mechanisms by the legal entities evaluated.

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 2022, the compliance team assigned 2,294 GRIs to our suppliers.

Also in relation to our suppliers, we have developed evaluation mechanisms that aim to guarantee that they have adequate technical, economic-financial, legal and HSE practices, in addition to having an ethical profile in their relationship with society and the environment.

In this way, we keep our supplier base active, with the objective of evaluating, prior to the conclusion of the contract, the companies in terms of meeting the technical, economic-financial, legal, integrity risk and HSE requirements. Our supplier evaluation has been continuously optimized and simplified, seeking to generate more value for the process. In 2022, we evaluated 2,611 companies on technical grounds; 3,604 companies on economic and financial grounds; 10,122 companies regarding legal requirements; and 419 companies regarding HSE requirements.

Integrity Background Check

The Integrity Background Check (BCI) is an integrity mechanism that seeks to support managers and senior management in decision-making regarding the nomination of candidates for key positions, through the analysis of legal requirements and compliance with our Code of Ethical Conduct and our Manager Appointment Policy.

In 2022, we conducted 3,787 Integrity Background Check assessments.

Conflicts of interest prevention

In addition to complying with article 115 §1 of law 6,404/1976 (Brazilian Corporations Law), law 12,813/2013 (Conflict of Interests Law) and law 13,303/2016 (State Companies Law), we have instruments that are continuously improved to deal with the identification and management of potential conflicts of interest relating to our managers and other employees.