inadequate “tone at the top” regarding internal controls, failure to communicate the ethical values prescribed in the Company’s Code of
Conduct, and lack of an effective whistleblower program;
deficiencies related to monitoring the need to reclassify certain property, plant and equipment from assets under construction to completed
property, plant and equipment;
failure to identify the need to write down payments advanced to contractors and suppliers that will not result in future economic benefits
and failure to identify the need to recognize expenses related to the termination of these contracts;
deficiencies related to the review of changes in certain groupings of exploration and production assets as cash generating units (CGUs), their
compliance with International Financial Reporting Standards, and changes in circumstances that affected the way certain CGUs generate
cash;
failure to timely monitor possible changes in the control parameters of the enterprise resource planning (“ERP”) environment, which are
used to support the internal controls related to the review and approval of manual journal entries, and deficiencies in the design of the
internal control over review and approval of manual journal entries;
deficiencies in control operations related to granting access procedures and segregation of duties analysis at the business process level;
deficiencies related to controls for capturing and registering in the Company’s internal monitoring systems the legal proceedings to which the
Company is party, the completeness of legal contingencies and accuracy of the classification of the possibility of an outflow of resources for
each contingency as probable, possible or remote; and
deficiencies related to the completeness of participants and accuracy of their individual information in the data generated for the actuarial
calculation.