During the year talks were given to new managers, supervisors and new employees, to reinforce the topics and curb any practices harmful to Petrobras

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Public commitment toethical principles

The Petrobras Code of Ethics is an important tool that defines the principles and guides the company’s actions and commitments of conduct. The Code explains the ethical meaning of the Petrobras Mission, Vision and Strategic Plan and consists of a public commitment to consolidate these principles in concrete everyday practices.

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The company revised the Code in 2005 to adapt it to the requirements of the Sarbanes-Oxley Act, which provides the approach of specific items for companies in the New York Stock Exchange. During its update, seminars were held to build the new Code in various units and subsidiaries, involving clients, suppliers, executive board, board of directors and the entire workforce in a transparent and participative process.

The document includes the members of the boards of directors, fiscal councils, executive boards, managers, employees, interns and services providers in the Petrobras System. The Code is available for download on the Petrobras worldwide web site.

PETROBRAS COMMITTEE OF ETHICS

In 2008, the Executive Board formed the Committee of Ethics in order to foster, guide and fulfill the ethical principles and commitments of conduct set in the Petrobras Code of Ethics. The Committee is linked to the Petrobras CEO’s Office and has an executive secretariat that helps compliance with the working plan and provides material and technical support for doing its duties.

With meetings held every two months, and extraordinary meetings being called to address specific or emergency matters, the Committee of Ethics handles all minutes of meetings in accordance with the information secrecy regulations adopted by the company.

All acts, proposals and/or recommendations to adopt disciplinary measures are as stated in Petrobras corporate regulations. The Committee consists of seven members, all company employees, and its duties are:

• > to guide, disseminate and encourage compliance with the ethical principles and commitments of conduct established by the Code of Ethics, accompanying its implementation, development and monitoring in the company;
• > to guide the Committees of Ethics of the subsidiaries in the Petrobras System;
• > to propose updates of the Code of Ethics by including new concepts and new practices, guaranteeing alignment to the Code of Professional Ethics of the Federal Executive Civil Servant;
• > to propose the creation or update of the company regulations with focus on improving the ethics management;
• > to investigate, by denunciation or official order, any conduct failing to adopt the relevant ethical standards in situations that go beyond the jurisdiction of the executive managers or that present a risk for the company image or business and issue recommendations.

TRANSPARENCY AND CORPORATE INTEGRITY

Petrobras investigates denunciations forwarded by the Ombudsman’s Office, CAS, external control entities – the Federal Audit Court and Federal General Controllership – and by the Department of Justice. The Business Protection management investigates the involvement of employees in any deviation of conduct, preventing the occurrence of acts of corruption. When situations that require special attention arise, audits in the units are proposed. At the same time, the Information Security area takes actions relating to the preservation and enhancement of internal controls, which contributes to preventing undue practices.

Petrobras employee training is based on anti-corruption policies and procedures. All the company’s business units undergo actions to assess corruption-related risks. During the year, talks were given to new managers, supervisors and new employees, to reinforce the topics and curb any practices harmful to Petrobras.

The company also carries out corporate campaigns to disseminate the principles expressed in its Code of Ethics, countering nepotism and refusing actions of favoring or receiving undue benefits.

Petrobras follows the guidelines of its Code and does not contribute to political parties or campaigns of candidates to elective positions. Conducting company business requires transparency in the actions and positions adopted, especially with regard to information passed on to society. Petrobras rejects any practice of corruption and bribery, and uses management tools such as the codes of Competitive Conduct and Best Practices, as well as the Federal Senior Administration Code of Conduct, whose application is controlled by the Committee of Public Ethics of the President of the Republic’s Office.

Petrobras is signatory of the Partnering against Corruption Initiative (Paci), with the objective of harmonizing the handling of corruption-related problems. To do this, there is a zero-tolerance policy against bribery and corruption.

The company is also committed to Extractive Industries Transparency Initiative (Eiti), a voluntary initiative that supports the efforts of countries rich in natural resources for better governance with the complete publication and verification of payment of companies and income of governments from the oil, gas and mining sectors.

Petrobras contributes by preparing and adopting general public policies and programs and specific projects focusing on sustainable development.

In addition, it valorizes the involvement of its employees in discussions for drafting proposals, which encourages social projects, in actions combined with public and private, governmental and non-governmental organizations.

The Petrobras Business Committee approved the process of relating to the Legislative Power and the creation of the Permanent Advisory Group (GPA) for coordinating the defense of the company’s interests in this sphere. In 2008, priority was given to 168 proposals comprising the Petrobras Legislative Agenda, 97 of which being processed (57.7% of the Agenda).

The idea of the relationship of Petrobras with federal authorities is to provide experience and skills for enhancing Brazilian policies in the company’s areas of influence. During the year, Petrobras participated in Conama committees and technical chambers and helped coordinate the IND P&G-8 Project – Enhancing Environmental Licensing of Prominp – for activities in the oil and natural gas sector, and which seeks to effectively contribute to developing the oil industry in Brazil.

At public hearings, Petrobras was represented in Congress to gather information about the actions underway in the Executive sphere. The company accompanied processes such as major setbacks for accepting the rights of those who received amnesty, explanations about the leak of information on the discovery in Santos Basin, discussions on postponing the implementation of the Vehicle Emission Control Program (Proconve) and discussions on the Discovery and development of new oil basins in the pre-salt layer.

Petrobras has strict internal and external controls and seeks to reach efficient solutions for all conduct deviations, punishing those involved in conformity with the law and corporate regulations. Cases registered in 2008 did not configured a crime; their authors were sanctioned and the processes were enhanced to restrict other occurrences.

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