Summary
Details
- Global
Mandatory obligations include:
Ethical Conduct Guide compliance.
legal and regulatory compliance.
integrity and anti-corruption compliance.
cooperation with procurement and contract management.
HSE compliance where relevant.
human rights and labour compliance.
accurate information in bids, prequalification and contracts.
supplier monitoring and performance evaluation.
corrective action where required.
Functionally mandatory obligations include:
emissions inventory publication for relevant suppliers.
CDP or CDP-compatible climate disclosure.
energy and fuel-consumption data.
HSE performance data.
environmental permit documentation.
climate change training participation, where requested.
ESG data for strategic categories.
subcontractor compliance evidence.
contract-specific sustainability requirements.
The strongest obligations apply to:
relevant suppliers under Petrobras’ GHG inventory target.
suppliers in strategic categories.
high-HSE-risk contractors.
offshore service providers.
FPSO-related suppliers.
drilling and subsea suppliers.
logistics and vessel suppliers.
refinery contractors.
engineering and maintenance providers.
suppliers subject to integrity evaluation and sanctions analysis.
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What’s Required
Petrobras’ supplier framework is a high-complexity procurement and compliance system. It should not be interpreted only as a supplier ethics policy. In practice, it operates as a private regulatory system for one of the largest oil, gas and energy supply chains in Latin America.
The governance architecture is built around:
Petrobras Supplier Channel.
Ethical Conduct Guide for Suppliers.
ESG Program for Suppliers.
supplier registration, screening and monitoring.
integrity due diligence.
ESG Journey for Suppliers.
CDP Supply Chain engagement.
sustainable contracting practices.
supplier performance evaluation.
health, safety and environment requirements.
climate change and emissions-related supplier engagement.
contractor management and sanctions analysis.
Petrobras sustainability, climate and energy transition reporting.
Petrobras states that ESG management of its supply chain is materialised through its ESG Program for Suppliers, covering internal ESG governance, category segmentation, procurement strategy development, identification of relevant suppliers and the stages of registration, contracting and contractual execution. This makes supplier sustainability a procurement-management function rather than a communications exercise.
1. Ethical Conduct Guide for Suppliers as a baseline compliance system
The Petrobras Ethical Conduct Guide for Suppliers applies to all suppliers, including companies based in Brazil or abroad, their affiliates and subsidiaries, and those involved in bidding, prequalification, direct contracting and contracts with Petrobras. The guide sets the principles, values and guidelines for Petrobras’ relationship with suppliers and reflects what the company expects from its supply chain.
Supplier obligations include:
ethical and transparent conduct.
compliance with laws and regulations.
anti-corruption and integrity controls.
respect for human rights.
prohibition of child labour and forced or slave labour.
safe and decent working conditions.
environmental responsibility.
cooperation with Petrobras compliance expectations.
accurate information in procurement and contracting processes.
behaviour compatible with Petrobras’ values and governance standards.
This creates a supplier conduct gate. Suppliers are not assessed only on technical capability, price and delivery. They must also be compatible with Petrobras’ integrity, human rights, safety and environmental expectations.
For Petrobras, this is especially important because supplier risk can arise in high-value, high-complexity contracts involving:
offshore platforms.
drilling services.
FPSOs.
subsea systems.
pipelines.
refineries.
industrial maintenance.
logistics and vessels.
fuels and chemicals.
engineering and construction.
digital and monitoring systems.
2. ESG Program for Suppliers and Sustainable Procurement
The ESG Program for Suppliers is one of the most important elements of the current Petrobras framework. Petrobras states that the programme covers category segmentation, procurement strategy development, identification of relevant suppliers, registration, contracting and contractual execution.
Supplier requirements may include:
ESG performance information.
environmental management data.
health and safety records.
climate-related information.
human rights and labour compliance evidence.
integrity and anti-corruption documentation.
supplier training participation.
corrective action implementation.
performance improvement plans.
evidence supporting sustainable contracting decisions.
This turns procurement into an enforcement mechanism. Petrobras can use supplier performance evaluation, monitoring, contract management and supplier development programmes to influence supplier behaviour.
The supplier framework is especially relevant because Petrobras’ supply chain includes highly specialised suppliers that are operationally critical to exploration and production, refining, gas, logistics and energy transition projects. In these areas, ESG failure can become operational failure.
3. Supplier monitoring, screening and contractual enforcement
Petrobras states that it monitors several ESG aspects in its supply chain and that these are reflected in processes with greater relevance to the business. The company identifies supplier screening processes such as integrity evaluation, performance evaluation, contract management and the Sanction Application Analysis Committee.
This creates a monitoring architecture covering:
integrity evaluation.
ESG screening.
performance evaluation.
contract management.
supplier monitoring.
sanctions analysis.
corrective action.
contract escalation.
potential supplier restriction or exclusion.
This is a clear private regulatory model. Petrobras does not merely ask suppliers to align with ESG principles. It embeds ESG and integrity controls into procurement screening, performance evaluation and contract execution.
For suppliers, this means compliance must be continuous. It is not enough to pass onboarding. Supplier performance can be monitored throughout contract execution, especially in strategic or high-risk categories.
4. ESG Journey for Suppliers and Capability Building
Petrobras’ Supplier Channel includes the ESG Journey for Suppliers, designed to improve sustainable contracting and supplier management practices. The training topics include Quality, Environment, Safety, Health, Climate Change, Human Rights and Compliance.
This is not only educational. It functions as a capacity-building and standardisation mechanism.
Suppliers may be expected to develop capability in:
climate change governance.
greenhouse gas emissions awareness.
environmental management.
occupational safety.
quality management.
human rights due diligence.
compliance and integrity.
contract documentation.
operational risk management.
For smaller or specialised suppliers, the ESG Journey may be the mechanism through which Petrobras transfers expectations from corporate policy into supplier-level practices. It also creates a common language for procurement, monitoring and corrective action.
5. Climate change, Scope 3 and CDP Supply Chain
Petrobras’ climate and supplier governance are complex because it operates in oil and gas. Supplier-related emissions are not the same as downstream use-phase emissions from sold fuels, but they are still material across purchased goods, capital goods, logistics, engineering services, maintenance, equipment, construction, vessels, energy and waste.
Supplier-linked emissions categories include:
capital equipment for exploration and production.
offshore platforms and FPSO supply chains.
drilling and subsea equipment.
refinery equipment and maintenance.
industrial services and contractors.
logistics, shipping and fuel transport.
electricity, fuels and energy services.
waste treatment and environmental services.
construction and engineering.
technology and digital systems.
Petrobras has joined CDP Supply Chain, encouraging suppliers to map emissions and provide transparency on governance, energy efficiency, emissions reduction, climate change and energy transition practices. Petrobras also states that it maintains a leading position in CDP’s Supplier Engagement Assessment, which evaluates supplier engagement on governance, climate targets, Scope 3 emissions and value-chain engagement.
Suppliers may need to provide:
Scope 1 emissions data.
Scope 2 energy and electricity emissions.
relevant Scope 3 emissions data.
fuel and energy consumption data.
vessel and logistics emissions data.
equipment efficiency information.
methane, leakage or flaring-reduction technology data.
waste treatment data.
contractor energy use.
climate governance information.
emissions reduction initiatives.
CDP-compatible disclosure.
This creates a climate-data obligation for relevant suppliers. Suppliers without emissions inventories, climate governance structures, or energy-efficiency documentation may become less competitive in Petrobras’ supplier ecosystem.
6. Relevant supplier emissions inventory target
Petrobras’ 2023 sustainability reporting stated a target for 70% of relevant suppliers to have their greenhouse gas emissions inventory published by 2028. It also referenced a commitment to evaluate, in 100% of contracts in strategic categories, the expansion of sustainability, social responsibility and corporate governance requirements to promote more sustainable and responsible practices in supply-chain operations.
This is a critical supplier governance signal.
Relevant suppliers may need to:
prepare a GHG inventory.
publish or disclose emissions information.
align inventory boundaries with recognized methodologies.
improve data quality over time.
respond to CDP or equivalent questionnaires.
disclose climate governance and reduction actions.
provide emissions data usable by Petrobras.
demonstrate progress toward emissions transparency.
This converts climate disclosure into a procurement expectation. Petrobras is not only tracking its own emissions. It is pushing suppliers toward emissions inventory maturity.
7. Health, Safety and Environment as operational supplier regulation
In Petrobras’ supply chain, HSE is a core enforcement category. Oil and gas suppliers often work in high-risk environments, including offshore installations, refineries, terminals, vessels, drilling operations, maintenance shutdowns and pipeline systems.
Supplier HSE obligations may include:
occupational safety management systems.
environmental permits and compliance.
emergency response plans.
contractor training and competence records.
incident reporting.
waste and hazardous material management.
spill prevention and response.
vessel safety controls.
refinery and offshore site access requirements.
personal protective equipment requirements.
air emissions and wastewater controls.
corrective action after incidents.
For Petrobras, HSE failure can result in human harm, environmental damage, operational shutdowns and regulatory exposure. Supplier HSE compliance is therefore not optional ESG behaviour. It is a core operational requirement.
8. Offshore, FPSO, engineering and industrial contractor controls
Petrobras’ supplier framework has particular relevance for high-value industrial categories, including offshore production systems and engineering services.
High-impact suppliers include:
FPSO suppliers and operators.
drilling contractors.
subsea equipment providers.
offshore vessel operators.
shipyards.
engineering, procurement and construction contractors.
refinery maintenance providers.
industrial automation suppliers.
rotating equipment suppliers.
pipeline contractors.
environmental emergency service providers.
These suppliers may need to provide:
technical qualifications.
HSE records.
emissions and fuel-consumption data.
integrity documentation.
labour compliance evidence.
contractor workforce information.
environmental permits.
equipment efficiency data.
waste and hazardous material controls.
operational risk assessments.
incident and corrective action records.
Supplier governance in these categories is stricter because failures can affect production continuity, emissions intensity, safety performance and environmental risk.
9. Logistics, marine transport and fuels
Petrobras’ supply chain also includes shipping, distribution, logistics, terminals, fuel transport and marine services. These suppliers are material to both operational efficiency and Scope 3-related reporting.
Logistics suppliers may need to provide:
fuel consumption data.
vessel emissions data.
route and distance information.
cargo handling data.
spill prevention measures.
terminal emissions and energy data.
transport safety records.
hazardous goods documentation.
emergency response capability.
emissions reduction initiatives.
Marine and logistics suppliers are especially relevant because oil and gas supply chains involve high-volume movement of fuels, equipment, raw materials and products. Weak logistics data can reduce Petrobras’ ability to quantify and manage supply-chain emissions.
10. Data systems and governance architecture
Petrobras’ supplier framework requires data systems capable of supporting procurement, ESG screening, CDP reporting, contract monitoring, HSE controls and performance evaluation.
Suppliers need systems covering:
supplier registration and qualification data.
ethics and integrity documentation.
emissions inventories.
CDP or CDP-compatible climate data.
energy and fuel data.
HSE records.
incident reporting.
environmental permits.
waste and hazardous materials documentation.
human rights and labour evidence.
contract performance data.
corrective action tracking.
sanctions and compliance records.
The data architecture challenge is significant. A Petrobras supplier may need to integrate information from operations, HSE, climate, legal, finance, HR and compliance teams. For major contractors, supplier ESG reporting becomes a cross-functional governance process.
11. Supplier segmentation and upstream cascade requirements
Petrobras’ ESG Program for Suppliers explicitly includes category segmentation and identification of relevant suppliers. This means supplier obligations are risk-based rather than identical for all vendors.
High-priority supplier groups include:
strategic category suppliers.
relevant suppliers for GHG inventory publication.
suppliers in high-HSE-risk categories.
suppliers subject to integrity evaluation.
suppliers in offshore and refinery contracts.
logistics and vessel suppliers.
high-emission contractors.
suppliers with large contract values.
suppliers affecting climate or energy transition objectives.
Upstream cascade requirements may include:
subcontractor HSE compliance.
workforce training across subcontractors.
emissions data from subcontracted operations.
human rights and labour controls in subcontracting.
anti-corruption and integrity obligations across subcontractors.
environmental permits and waste controls for subcontracted services.
corrective action flow-down.
This creates multi-tier private regulation. Subcontractors may not contract directly with Petrobras, but they can be pulled into Petrobras’ ESG, HSE and integrity requirements through prime contractors.
Important Deadlines
Key timelines include:
January 2024: Petrobras established ESG Management for the Supply Chain as the area responsible for supplier engagement and sustainable procurement strategy implementation.
2024 reporting year: Petrobras’ 2024 Sustainability Report covers the period from January 1, 2024, to December 31, 2024, with relevant early-2025 events included where indicated.
2025: Petrobras maintained a leading position in CDP Supplier Engagement Assessment based on its 2025 performance.
2028: target for 70% of relevant suppliers to have their GHG emissions inventory published, stated in Petrobras’ 2023 sustainability reporting.
Ongoing: Ethical Conduct Guide compliance for suppliers.
Ongoing: supplier monitoring through integrity evaluation, performance evaluation, contract management and sanction analysis.
Ongoing: CDP Supply Chain engagement and supplier emissions transparency.
Ongoing: ESG Journey training covering climate change, environment, safety, health, human rights and compliance.
Ongoing: annual sustainability reporting, with Petrobras stating that sustainability reports are published annually after financial statements and other specific documents.
Current Status
The framework is active, expanding and increasingly climate-data oriented. The creation of ESG Management for the Supply Chain in January 2024 indicates that Petrobras is institutionalising supplier sustainability within procurement strategy, supplier segmentation, supplier identification, registration, contracting and contract execution.
The framework is strongest in:
supplier ethics and integrity.
supplier monitoring and sanctions analysis.
ESG programme governance.
CDP Supply Chain engagement.
supplier GHG inventory expectations.
HSE and contractor controls.
strategic category supplier management.
climate change training through the ESG Journey.
It is less similar to consumer goods or chemicals frameworks that rely heavily on product carbon footprints, but it is highly consequential because Petrobras suppliers operate in high-risk, emissions-intensive and safety-critical oil and gas environments.
Penalties for Non-Compliance
Enforcement is procurement-driven.
Potential consequences include:
failed supplier registration or prequalification.
negative integrity evaluation.
corrective action requirements.
lower supplier performance evaluation.
contract management escalation.
review by the Sanction Application Analysis Committee.
reduced sourcing opportunities.
suspension from procurement.
contract penalties.
contract termination.
reputational exposure.
restriction on future bidding.
regulatory exposure where supplier failure causes environmental or safety incidents
The strongest enforcement mechanism is access to Petrobras’ procurement system. A supplier that cannot meet integrity, HSE, ESG, climate-data or contract requirements becomes commercially and operationally risky.
Examples of Known Violations
This analysis does not identify specific public violations by named Petrobras suppliers. Realistic failure modes include:
failure to comply with the Ethical Conduct Guide.
incomplete integrity due diligence documentation.
weak anti-corruption controls.
lack of published GHG inventory by relevant suppliers.
incomplete CDP response.
poor HSE performance.
offshore incident reporting failures.
weak contractor training records.
missing environmental permits.
hazardous waste or spill management failures.
incomplete fuel or logistics emissions data.
human rights or labour non-compliance in subcontracting.
failure to implement corrective actions.
poor contract performance evaluation.
sanctions-triggering conduct.
These failures can affect supplier approval, contract continuity, future bidding eligibility and reputational standing.
Resources
https://canalfornecedor.petrobras.com.br/en/compliance/gestao-asg-para-fornecedores
https://canalfornecedor.petrobras.com.br/en/compliance/monitoramento-de-fornecedores
https://canalfornecedor.petrobras.com.br/en/compliance/mudancas-climaticas
https://canalfornecedor.petrobras.com.br/en/compliance/sustentabilidade
https://canalfornecedor.petrobras.com.br/en/compliance/compliance
https://sustentabilidade.petrobras.com.br/en/w/sobre-o-relatorio
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