Petrobras to Implement New Integrity Due Diligence Questionnaire (DDI)

Comments by partner Mauricio Bove, Head of the Compliance Practice at LP Law

According to the company, the updated version of the questionnaire will feature improved wording and clearer definitions of key concepts, all aimed at enhancing comprehension and promoting the quality of responses and supporting evidence provided by suppliers.

A challenge for many companies seeking to participate in Petrobras tenders, the methodology applied by the company is risk-based, and considers factors such as:

• The company’s profile and size

• Its relationships with public officials

• Any history of fraud and/or corruption

• The use of intermediaries, among others

  
  

These factors are cross-checked against documentary evidence of the existence and effective implementation of integrity measures, including mechanisms for prevention, detection, and remediation of irregularities.

In an official statement, Petrobras noted:

“The improvement of the questionnaire is mainly based on the history of assessments carried out since August 2015. To date, thousands of suppliers have been evaluated using the questionnaire, which has allowed us to reflect our accumulated experience in the document.”

Recently, LP Law | Lopes Pinto Advogados Associados assisted a Petrobras supplier whose Integrity Risk Rating (GRI) had been initially classified as “high.” To reverse this status, LP LAW worked with the client to assess the integrity measures already in place, secure top management engagement, and conduct a thorough risk analysis.

The client appointed a Compliance Officer, and together we conducted a comprehensive review of the compliance program. We examined Petrobras’s concerns and questions in detail and responded in a complete, open, transparent, and well-documented manner for each component of the program.

The Result

In a short time—and following significant effort—the client’s GRI was reclassified from "high" to "low" by Petrobras, allowing the company to continue contracting with the state-owned enterprise.

In its statement, Petrobras also emphasized:

“The better and more complete the responses, the more accurate the assignment of the Integrity Risk Rating (GRI)—High, Medium, or Low—for potential suppliers will be.”