Rio de Janeiro, December 1, 2015 – Petróleo Brasileiro S.A. – Petrobras hereby responds to CVM Official Letter 500/2015/CVM/SEP/GEA-1 requesting clarifications, as transcribed below:

CVM Official Letter 508/2015/CVM/SEP/GEA-1

“We refer to the news item published on November 29, 2015 in the Poder (Power) section of the newspaper Folha de São Paulo, entitled Petrobras deu US$ 1 bi a investigadas, diz revista (Petrobras gave US1 billion to companies under investigation, claims magazine), which states that:

Petrobras has gone back on its decision at the end of last year to not continue doing business with 23 companies under investigation by Operation Car Wash due to their involvement in cases where there is suspicion or proof of bribery.

Petrobras found a roundabout way of transferring approximately US$1 billion, equivalent to around R$3.8 billion today, to two shipyards, according to Época magazine.

The transfers took place as of May this year. All the companies under investigation by Operation Car Wash are suffering financial difficulties precisely because they were prevented from entering into contracts with Petrobras until the suspicion of paying bribes was lifted.

The beneficiaries are shipyards controlled by Odebrecht, OAS and UTC (Enseada) and Engevix (Ecovix).

[…]

ALERTS

Petrobras’ legal department was opposed to the operation to help the shipyards, according to a document obtained by the magazine’s reporters.

‘One cannot ignore the involvement of companies controlled by the partners in the shipyards in illicit acts currently under investigation by Operation Car Wash,’ it stated.

Justice Sergio Moro once again recommended that Petrobras not do business with the companies under investigation.

The transfers were made through an escrow account – a rapid means for contractors to receive funds from Petrobras. All the companies have to do is present invoices proving their expenditure on the works to receive payment through the escrow account.

Under normal conditions, payment is made only after confirming that that the service was in fact rendered in accordance with the contractual conditions, which is a much lengthier process.

Given the above, we would like you to confirm if the content of this news item is in fact true and, if so, why such information was not deemed to constitute a material fact,”.

Clarification

Petrobras would like to make it clear that the objective of the escrow accounts is to maintain the continuity of certain strategic projects included in the 2015-201 Business and Management Plan.

The escrow account is an exceptional contractual management support mechanism designed to ensure greater control over the application of funds for compliance with the contractual object by the contracted party in cases where possible nonperformance could have a greater adverse impact on Petrobras.

A series of technical, financial and legal analyses were carried out in regard to the implementation of the escrow accounts, whose results were submitted to the approval of the Executive Boards of Petrobras and the partner companies.

The restriction order, an important preventive measure adopted by Petrobras, remains in force, preventing companies under investigation from taking part in bidding processes and entering into new contracts. Only suppliers who have passed through a due diligence process to verify their integrity, in which detailed information on their structure, finances and compliance and fraud and corruption combat mechanisms are subject to rigorous examination, may take part in such processes. In addition, the imposition of restriction orders does not imply the suspension of ongoing contracts, which includes those cited in the news item.

Finally, it is worth noting that the suppliers and sub-contractors who receive payment through an escrow account are not companies subjected to a restriction order by Petrobras.