DECRETO 2745 PETROBRAS PDF

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Cancel OK. File name: -. File size: -. Title: -. Author: -. Subject: -. Keywords: -. Creation Date: -. Modification Date: -. Creator: -. PDF Producer: -. PDF Version: -. Page Count: -. Preparing document for printing…. The report further concluded that the processes analyzed did not contain a documented negotiation strategy that sought to achieve the best conditions for Petrobras, as described in item 6.

The report highlighted another non-conformity related tocontract Contract management was also done right. Review by Forensic Services We reviewed the investigation report and all physical investigative documents provided. We have reviewed all interview statements, analyzed in detail the final report issued by the CIA, to further understand the investigation plan and methods used, and, if any, the remediation and action plans undertaken and what they entailed.

Additionally, we have also reviewed emails that were mentioned in the report, as well as assessed if the e-discovery analysis was appropriate. Therefore, the work performed did not cover all allegations, which included disclosures in the media during or after the Commission's work. As part of our analysis of the interviews, we have listed the vendors mentioned in each statement, as well as persons mentioned in the interviews that were not interviewed that may have additional information to offer the CIA.

Conclusions Based on the review of this and other CIAS, PwC has concluded that the Company should pursue and independent investigation of the allegations of corruption and fraud in connection with the retention of Astromaritima and the involvement of Mr. Observations regarding management's conclusions As outlined in Section 8. Why this is in compliance with the relevant acquisition rules is not fully explained in the CIA Report.

Francisco Matos dos Santos, Mr. Milton Linhares, Mr. Alcir Bourbon Cabral and Estate of deceased Mr. Renato de Andrade Cabral; o And Mr. Paulo Roberto Costa. Paulo Roberto Costa, he confirmed his company Costa Global was used to receive bribe money that was due from the time he was Director at Petrobras. As such, the internal control analysis should evaluate the process to assure the strategies are always implemented and documented appropriately.

As such, the internal control analysis should evaluate if other contracts are not reflected correctly in the system and if there is a process in place to prevent or remediate such errors. Individuals interviewed by the Astromaritima Note that none of the individuals listed below were specifically considered in the priority phase of the external investigation. Toyo Setal CIA 9. Overview of allegations According to the Toyo Setal CIA Report, the internal investigation was triggered by media coverage on alleged irregularities regarding Toyo Setal.

The report goes on to detail the following items:. In October 28, , news website "Portal G1" reported: o Mr. Paulo Roberto Costa, was participating in a cartel with giant construction companies. Alberto Youssef. Participation in Cartel ii. Over Overpricing in bids where Toyo Setal participated, either directly or in a consortium. Nonconformities regarding Corporate Directions on Supply of Goods and Services in contracts and amendments, since The CIA released its report November 12, Define the methodology to define the practice of cartel.

Define the methodology to analyze period of time covered by investigation. Define the methodology to evaluate conformities in the macro process of Goods and Services Procurement.

List all subsidiaries and controlled companies by Toyo Setal group, and involvement with Petrobras. List all contracts in place with companies related to Toyo Setal, including joint ventures. List information related to the contracts that are going to be part of the scope. List and analyze audit reports from internal and external oversight units on the topic of this CIA. List occasional complaints in the Ethics Hotline regarding Toyo Setal. Apply the methods defined to analyze the contracts.

Interview individuals, if necessary. Judge findings, concluding and suggesting future recommendations. Conclusions of management's investigation In summary, Toyo Setal CIA concluded the prices were largely competitive with the exception of a few irregularities that were found in the bidding processes. Indication of overpricing Based in Information gathered and evaluated for the items acquired, the Toyo Setal CIA concluded that the prices bid were competitive and were inside the range of acceptability from Petrobras cost estimate.

Petrobras estimate is developed in detail by the market value prices of each component; unit costs of raw material necessary and indirect expenses such as meals, transportation and taxes. Conformity with bidding process i. Modules from P No relevant or "moderate nonconformities" were identified for this project. UFN V No relevant or "moderate nonconformities" were identified for this ject.

Indication of cartel The Toyo Setal CIA concluded that, despite the apparent price arrangement in some tenders, on balance, there is a reasonable level of competition in the bids. Actions and strategies adopted by Petrobras mitigated the potential for payment for above market prices, resulting in the execution of contracts with competitive prices.

Regarding the relationship with Petrobras and its managers a. TSPI's chairman is Mr. Interview with Mr. Francisco Pais executive manager for Mr. Francisco Pais, and former directors, Mr.

Paulo Roberto Costa and Mr. Renato Duque. Francisco Pais had 22 meetings in and 21 meetings in with Mr. In his interview he explained we would host Mr. Paulo Roberto Costa, mostly to talk about ongoing projects. The interview mainly discusses the relationship in between Mr. Francisco Pais and Mr. The interview does not clarify the purpose of the number of meetings held with Toyo Setal or whether any improper arrangements were made. We understand that due to the nature of the CIA, the scope of work was limited to analyze facts and data related to Toyo Setal.

Therefore, the work performed did not cover all allegations contained in the media. We also note that this CIA lasted for only 8 days. Conclusions Based on the review of this CIA, PwC has concluded that the Company should pursue and independent investigation of the allegations of corruption and fraud in connection with the Toyo Setal contracts. Observations regarding the investigation report As outlined in Section 9.

Based on our review the physical investigative documents, and media coverage, we would consider the following additional conclusion: Comparison of the contract prices in the Toyo Setal contracts with market price benchmarks and determining whether or not such prices fall within a reasonable range is not an investigative method that deals with the allegation that a portion of the contract price was earmarked to compensate Mr.

The conclusions regarding the relationship with Petrobras and its managers are not conclusions. The report only indicates the ownership of Toyo in contracts that were in the scope of the investigation solely because Toyo participated and won such bids. Topics for further investigation As part of the external investigation to be completed, we would recommend that the following items be considered: Analyze, interview and investigate employees that participate in the relationship with Toyo Setal, in bidding process, contract signing, service measurement and contract management.

Franciso Pais, as well as connection to Mr. Investigate irregularities on contracts between Petrobras and all other companies in Lava Jato operation. Items to consider in the internal control review The Toyo Setal CIA does not detail any internal controls recommendations.

However, based on our review, the following items may be considered: Identify and evaluate controls in place for the security of internal estimates, and whether this information is being sent to vendors, in order to place their bids inside this range. Sanko Sider CIA Allegations and the subsequent investigation by management

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