SBM Offshore reports on significant fines paid by SBM Offshore and all affiliate companies. To define a significant fine the following thresholds are considered (subject to final assessment by Management Board on a case by case basis):
Operational fines of a regulatory and/or administrative nature which exceed US$ 500,000
No significant operational fine had to be paid in 2018.
Legal and compliance fines of a criminal nature
which exceed US$ 50,000
During 2018, two cases brought through Brazilian dispute resolution mechanisms led to significant fines to be paid by the Company:
- On July 26, 2018, the Company signed a Leniency Agreement with Brazilian Ministry of Transparency and Comptroller’s General Office (Ministerio da Transparencia e Controladoria-Geral da Uniao – ‘CGU’), the Attorney General’s Office (Advocacia Geral da Uniao – ‘AGU’) and Petrobras. The Leniency Agreement provides for:
- On September 1, 2018, the Company reached resolution with the Brazilian Federal Prosecutor’s Office (Minesterio Publico Federal – ‘MPF’), by means of an agreement that provides for a fine of BRL 200 million (approximately $48 million as per December 31, 2018) to be paid by the Company to Petrobras. As with all such agreements signed by the , this agreement is subject to approval by the Fifth Chamber of the .
The legal fines and compensations for alleged damages amount to US$ 374 million. With the signing of the agreements mentioned above, the Company is allowed to resume normal business activities with Petrobras.