Petrobras has included compliance with its Conduct Guide in the latest version of its Procurement Manual, a document that compiles guidelines to be followed by Petrobras and its suppliers when entering into contracts.The Conduct Guide, which complements the Petrobras System’s Code of Ethics and includes practical details about how to implement the Code, providing guidance on everyday conduct, was approved by the Executive Board in November 2014. This is another step in the company’s drive to ensure compliance with processes and mitigate risks, including fraud, corruption and ethical misconduct risks.

To produce the Guide, the company looked at similar well-regarded documents across the world, consulted business areas and subsidiaries, and analyzed internal rules and national and international legislation, especially regarding corruption and conflicts of interest. The document’s guidelines include "Do not imply, request, demand or accept, nor offer, promise or give any kind of favor, advantage, benefit, donation, gratuity or bribe, for the benefit of yourself or another person, in exchange for actions by yourself or third parties."

Petrobras’ Procurement Manual provides for the following penalties for hired companies that practice illegal acts that harm it: warnings, fines, suspension of contracts, and a ban on participating in bid processes and signing new contracts.

The Conduct Guide must be followed by members of the Board of Directors, Audit Council and Executive Board, Petrobras System employees and interns, and the employees and interns of service providers. Through the guide, Petrobras aims to reinforce the prevention of misconduct, promote the communication of guidelines and educational activities, and spread knowledge about the application of appropriate disciplinary measures when any misconduct is identified.