SEVAN MARINE ASA

Industry

Extractive Industries/Mining/Oil & Gas

Corporate Headquarters

Arendal, Norway

Summary of Allegations:

Nationality of Foreign Officials: Brazil

Summary of Allegations:

In June 2015, Sevan Marine engaged the law firm of Selmer to initiate an independent corporate investigation into the circumstances and facts surrounding the Petrobras contracts, in response to Brazilian press articles which refer to a former manager and agent of Sevan Marine being named in connection to the Petrobras scandal.

On 16 October 2015, Sevan Marine announced that the Board has received the investigation report from Selmer which concluded that it is more likely than not, that illegal conducts in the form of improper payments to obtain business occurred when Petrobras awarded contracts to Sevan from 2005 to 2008 with regards to Sevan Piranema, Sevan Driller and Sevan Brasil. The report alleged that there were indications of suspicious acts and transactions, constituting both a neglect of Sevan's affairs and/or a conflict with Sevan's interests and such acts may potentially represent economic crime. Furthermore, the report alleged that the possible wrongdoings identified were connected to former Sevan employees.

Approximate Alleged Payments to Foreign Officials: Unspecified

Business Advantage Allegedly Obtained: Unspecified

Enforcement Results

Agencies: Brazil: Unspecified

Results:

Year Resolved:

Compliance Monitor:

Ongoing: Yes

Details:

On 16 October 2015, Sevan announced that the company has initiated early contacts with the relevant prosecutors' office in Brazil in coordination with counsel retained in Brazil.

Agencies: Norway: National Authority for Investigation and Prosecution of Economic and Environmental Crime

Results:

Year Resolved:

Compliance Monitor:

Ongoing: Yes

Details:

On 16 October 2015, Sevan announced that the company has provided the internal investigation report to the Norwegian National Authority for Investigation and Prosecution of Economic and Environmental Crime ("ØKOKRIM") in coordination with counsel retained in Norway.

Agencies: United Kingdom: Unspecified

Results:

Year Resolved:

Compliance Monitor:

Ongoing: Yes

Details:

On 16 October 2015, Sevan announced that the company has initiated early contacts with the relevant prosecutors' office in the United Kingdom in coordination with counsel retained in the United Kingdom.

Agencies: United States: Department of Justice, United States: Securities and Exchange Commission

Results:

Year Resolved:

Compliance Monitor:

Ongoing: Yes

Details:

On 16 October 2015, Sevan announced that the company has initiated early contacts with the relevant prosecutors' office in the United States.

ENTITIES / INDIVIDUALS INVOLVED
  • Sevan Marine ASA ("Sevan")
  • Petroleo Brasileiro SA ("Petrobras")
Details Of How Conduct Was Discovered

Discovery Method: Voluntary Disclosure

Details:

Sevan voluntarily disclosed the findings from their internal investigation to the relevant authorities in Norway, United States, United Kingdom and Brazil in 2015.

Country: