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THE SHELL LEAKS FILES — 31 OCTOBER 2026 SLF-2007-104 The Sakhalin Papers XCIV: The Blending Loophole — Russian Oil in Shell’s Supply Chain After the Apology

By John Donovan — 31 October 2026

On 8 March 2022, Shell apologised for purchasing discounted Russian crude oil and announced its intention to withdraw from Russian hydrocarbons. Yet its trading arrangements continued to permit purchases of certain refined petroleum products containing almost 50% Russian-origin material. Bloomberg exposed the practice in April. Ukraine’s government accused Shell of exploiting an accounting trick. Shell disputed the allegation that it was deliberately purchasing Russian products for blending and resale. On 27 April, Reuters reported that the company had tightened its trading terms to exclude refined products containing any Russian-origin material. The surviving corporate statements, contemporaneous trading reports and official sanctions records reveal what happened — and the important distinction between a contractual loophole, an actual purchase and an unlawful transaction.

Archive reference: SLF-2007-104
Publication date: 31 October 2026
Collection: The Sakhalin Papers — Shell, Gazprom and Russia
Previous instalment: SLF-2007-103 — The Discounted Cargo, 30 October 2026

Principal documentary evidence: Shell’s announcement of 8 March 2022; Bloomberg’s examination of Shell’s trading terms, 8 April 2022; the letter dated 13 April from Ukrainian presidential adviser Oleg Ustenko, as reported by Bloomberg; Shell’s response reported on 22 April; Reuters’ examination of revised Shell trading terms, 27 April; UK government statements and subsequent sanctions legislation; European Union sanctions records.

Evidence classification: Authenticated corporate statements, contemporaneous reporting based on observed trading bids, attributed government correspondence, official regulatory records and separately identified editorial commentary.

Important evidential limitation: The relevant trading conditions are documented through contemporary Bloomberg and Reuters reporting. The complete original Shell trading contracts, cargo-level transaction records and the original Ukrainian letter have not been independently obtained for this instalment. Their reported contents are distinguished from documents examined directly.

Introduction: When does Russian oil stop being Russian?

The question sounds almost absurd.

If a petroleum product contains Russian oil, surely it remains at least partly Russian.

But international commodity trading does not operate according to such simple definitions.

Petroleum products may be blended with equivalent products originating in other countries.

Crude oil may be refined outside the country where it was extracted.

Cargoes may be transferred between vessels.

Products may pass through several storage terminals, traders and intermediaries before reaching their ultimate purchasers.

The resulting questions concerning origin, ownership and contractual restrictions can become extraordinarily complicated.

In April 2022, those complications became a public-relations crisis for Shell.

The company had already apologised for purchasing Russian crude after the invasion of Ukraine.

It had promised to cease spot purchases of Russian crude and withdraw from Russian hydrocarbons more broadly.

But an examination of its trading terms revealed that certain refined products containing less than 50% Russian-origin material could still qualify for purchase.

The practice became associated with a term used by commodity traders:

The Latvian blend.

Ukraine’s government protested.

Shell defended its conduct.

Then, on 27 April 2022, Shell confirmed that it had changed its purchasing requirements.

The revised conditions excluded refined products containing Russian-origin material, even when blended with products from other countries.

This instalment reconstructs the sequence using contemporary documents and reporting.

The central question is not whether blending petroleum products is inherently unlawful.

It is whether Shell’s purchasing rules adequately reflected its publicly declared commitment to withdraw from Russian hydrocarbons.

The answer requires careful distinctions between established facts, contested allegations and matters that remain unverified.

1. The March apology: What Shell actually promised

On 8 March 2022, Shell issued the statement examined in the previous instalment.

Chief executive Ben van Beurden apologised for purchasing a cargo of Russian Urals crude oil after the invasion.

The company’s announcement went substantially beyond the narrower withdrawal from Russian equity partnerships announced on 28 February.

Shell declared that it intended to withdraw from involvement in Russian hydrocarbons, including crude oil, petroleum products, pipeline gas and liquefied natural gas.

But the announcement contained an important qualification.

The withdrawal would proceed “in a phased manner.”

Shell committed to immediately stopping spot purchases of Russian crude oil.

It also undertook not to renew term contracts.

The company acknowledged that removing Russian crude from its supply chain could take weeks.

Withdrawing from Russian petroleum products, pipeline gas and LNG was expected to take considerably longer.

These distinctions were explicit in Shell’s original statement.

The company was not promising that every existing contractual obligation or physical delivery involving Russian energy would disappear immediately.

Its commitment concerning crude-oil spot purchases was immediate.

Its withdrawal from other Russian hydrocarbons was progressive.

That difference subsequently became central to Shell’s defence of its trading arrangements.

However, the broader public message was clear.

Shell intended to cease its involvement in Russian hydrocarbons.

For a company already facing criticism over its discounted crude-oil purchase, the scope and implementation of that commitment were matters of substantial public interest.

Primary source: Shell’s original announcement, 8 March 2022. Shell

2. A trading condition that changed the meaning of origin

The controversy developed around contractual definitions used in Shell’s trading operations.

In April 2022, Bloomberg columnist Javier Blas examined provisions governing the company’s purchases of petroleum products.

The relevant arrangements distinguished between products classified as Russian-origin and those classified as non-Russian.

The critical issue was the proportion of Russian material in a blended product.

According to Bloomberg’s examination, products containing less than 50% Russian-origin material could fall outside Shell’s contractual definition of Russian-origin products.

A cargo containing 49.99% Russian material and 50.01% material from elsewhere could therefore satisfy the non-Russian-origin condition described in the report.

This was not a claim that Russian oil had physically ceased to exist.

The Russian material remained present.

The issue was how the product was classified for the purposes of Shell’s purchasing conditions.

This distinction requires emphasis.

A private contractual definition of origin is not automatically a rule established by international sanctions law.

There was no universal legal principle under which mixing 49.99% Russian petroleum with 50.01% non-Russian petroleum automatically made every resulting transaction lawful.

The applicable legal position depended on jurisdiction, the particular sanctions in force, the nature of the product, its actual origin and the relevant customs and sanctions rules.

The arrangement reported by Bloomberg concerned Shell’s own trading conditions.

It was therefore primarily a question about corporate purchasing policy and the implementation of Shell’s public commitments.

Bloomberg published its investigation on 8 April 2022.

It became the principal source for the controversy that followed. Bloomberg.com

3. The Latvian blend: A term from the commodity markets

The expression Latvian blend was not the name of a separate geological oil field.

It was a term associated with blending Russian petroleum products with material originating elsewhere.

Bloomberg described commercial arrangements involving Russian diesel transported through Baltic export routes.

The port of Ventspils in Latvia was identified as one location associated with the practice.

Other blending locations mentioned in contemporary reporting included storage facilities in the Netherlands and transfers between vessels.

The commercial principle was relatively straightforward.

A petroleum trader could combine material from different sources to produce a cargo satisfying particular commercial specifications.

Blending is a normal feature of international petroleum trading.

Diesel, jet fuel and other refined products are frequently blended to meet quality specifications, seasonal requirements or contractual conditions.

That practice is not inherently suspicious.

The controversy arises when blending is used, or appears capable of being used, to change how a product’s origin is represented.

In April 2022, origin had become especially important because Russia’s invasion of Ukraine had generated pressure on energy companies to stop purchasing Russian hydrocarbons.

A product containing substantial quantities of Russian diesel could create a commercial and reputational dilemma if it was described as non-Russian solely because the Russian component was below a specified threshold.

The term Latvian blend became shorthand for that dilemma.

But an important qualification is necessary.

The label did not establish that every blended cargo was physically mixed in Latvia.

Nor did it establish that Shell itself operated a blending facility producing such cargoes.

The distinction between a trading-market expression and a verified physical transaction is fundamental. Bloomberg.com

4. Latvia’s response: The geography was also disputed

The Latvian aspect of the controversy received attention from the country’s own media and authorities.

On 12 April 2022, Latvian public broadcaster LSM reported that the relevant authorities intended to examine the circumstances described in Bloomberg’s investigation.

The report referred to possible blending involving Ventspils.

But it also recorded denials from operators associated with the port’s petroleum terminals.

Those operators disputed their involvement in the activities described.

This is an important piece of the documentary record.

The existence of blending arrangements within international petroleum markets does not establish that a specific Latvian company participated in them.

Nor does the use of the expression Latvian blend establish the geographical origin of every product described by that term.

The available reporting therefore supports a limited conclusion.

The controversy prompted scrutiny in Latvia.

Questions were raised about whether blending was taking place through particular facilities.

But the material examined here does not establish a regulatory finding that the named terminal operators had engaged in unlawful conduct.

The geographical allegations should not be treated as proved simply because the market terminology became widely used.

Contemporary source: Latvian Public Media, 12 April 2022 — Authorities Examine Reports of the Latvian Blend.

5. A March 30 trading bid provides a more precise documentary reference

One of the most useful details in the subsequent Bloomberg reporting concerns a specific trading bid.

According to data examined by Bloomberg, Shell sought to purchase ultra-low-sulphur diesel through the S&P Global Platts pricing process on 30 March 2022.

The conditions of the bid excluded Russian-origin cargoes.

However, the accompanying definition permitted blends containing less than 50% Russian-origin material.

This matters because it establishes more than a general allegation about industry practice.

It identifies a particular date, commodity and trading process.

The bid was placed more than three weeks after Shell’s 8 March apology.

But the evidential distinction remains important.

A bid demonstrates the terms on which a company was prepared to purchase.

It does not necessarily establish that the bid resulted in a completed transaction.

Nor does it establish that the resulting cargo, if purchased, contained the maximum amount of Russian material permitted by the conditions.

The figure of 49.99% became prominent because it illustrated the contractual threshold.

It should not automatically be presented as the verified composition of a cargo actually delivered to Shell.

The surviving public reporting identifies the purchasing condition.

It does not provide a complete cargo-by-cargo accounting of deliveries made under that condition.

That limitation prevents an allegation about contractual eligibility from being transformed into an unsupported assertion concerning specific shipments. gCaptain

6. Ukraine’s government challenges Shell again

The controversy attracted a direct response from Ukraine.

In a letter dated 13 April 2022, Oleg Ustenko, chief economic adviser to Ukrainian President Volodymyr Zelensky, challenged Shell’s position.

The letter was addressed to Shell chief executive Ben van Beurden.

Contemporary Bloomberg reporting also identified Shell’s legal director, Donny Ching, as a recipient of questions concerning the company’s trading rules.

The letter expressed concern that Shell’s purchasing conditions appeared to permit continued dealings in products containing Russian petroleum.

Ustenko characterised the arrangement as an accounting device through which companies could continue supporting Russian energy revenues while publicly claiming to have withdrawn.

He described the alleged practice as deplorable.

The letter raised questions concerning the treatment of cargoes containing less than 50% Russian material.

It also sought clarification about whether such cargoes would comply with restrictions in other jurisdictions, including the United States and the United Kingdom.

Another question concerned the quantities of blended oil Shell might still be lifting from Russian ports under longer-term arrangements.

These were important questions.

They went beyond the immediate issue of a purchasing condition.

They sought to establish whether Shell’s contractual definitions were consistent with the practical consequences of its public withdrawal commitment.

The criticism also followed an earlier confrontation.

In March, Ukraine’s foreign minister, Dmytro Kuleba, had condemned Shell’s purchase of discounted Russian crude.

The April letter therefore represented a second major Ukrainian challenge to Shell’s Russian petroleum trading activities.

However, the letter was an expression of the Ukrainian government’s concerns and allegations.

It was not a judicial finding.

Its contents were reported by Bloomberg and other contemporary media organisations.

The original signed letter has not been independently examined for this instalment.

That distinction is retained. gCaptain

7. Shell’s response: The company disputed the central accusation

Shell did not accept the suggestion that it was deliberately purchasing Russian products for blending and resale under a non-Russian label.

In a response reported by Bloomberg on 22 April, a Shell spokesperson denied that the company had purchased products exported from Russia for that purpose after its 8 March withdrawal announcement.

The company also said it had stopped spot purchases of Russian crude and LNG.

Shell stated that it had eliminated the vast majority of spot purchases of refined products that might contain Russian material blended earlier in the supply chain.

This response deserves careful treatment.

Shell was making a specific denial concerning deliberate purchases of products exported from Russia for blending and subsequent resale as non-Russian.

That is not identical to denying that its contractual terms had contained the 50% definition.

Nor is it identical to claiming that every petroleum product purchased anywhere in its supply chain was completely free of Russian material.

The company acknowledged that refined products could contain Russian-origin components introduced earlier in the supply chain.

It also maintained that it was working to reduce and eliminate those exposures.

The distinction is significant.

The company’s response supports the conclusion that Shell regarded the withdrawal as an ongoing process.

It also illustrates why the contractual wording attracted criticism.

A company could intend to eliminate Russian petroleum while retaining purchasing conditions that permitted some Russian-origin material in blended products.

Whether particular transactions were consistent with the company’s commitments depended upon their actual circumstances.

Shell’s statement cannot independently establish that every transaction complied with its policy.

Equally, the existence of permissive contractual language does not establish that Shell deliberately purchased Russian oil to disguise its origin.

Both propositions would require additional transaction-level evidence.

Contemporary source: Bloomberg — Ukraine Criticizes Shell’s Rules on Russian Fuel Purchases, 22 April 2022.

8. The Donovan–Shell archive preserved the controversy as it unfolded

An important feature of this investigation is that RoyalDutchShellPlc.com was recording the developments in April 2022.

The archive contains contemporary articles examining the Latvian blend controversy, Ukraine’s objections and Shell’s response.

On 22 April, the website published a report from City A.M. describing the Ukrainian government’s accusations and Shell’s denial.

Other contemporary coverage preserved by the archive included reporting from The Telegraph and the Daily Mail.

The archive subsequently published Reuters’ account of Shell tightening its trading terms on 27 April.

These records are valuable because they establish what was being publicly reported at the time.

They also help preserve the sequence of events.

This is particularly important when investigating corporate controversies retrospectively.

A later account can sometimes compress several distinct events into a single narrative.

The original reports show a more complicated progression.

Shell’s withdrawal announcement came first.

The contractual definition attracted scrutiny.

Bloomberg’s investigation brought the issue into wider public discussion.

Ukraine’s government challenged Shell.

Shell responded.

The company then tightened its trading requirements.

The archival record also demonstrates why contemporaneous reporting should be preserved with its original date and attribution.

The City A.M. report and the Bloomberg account do not constitute separate independent confirmation of every allegation.

Both drew upon the same underlying controversy and statements.

Their value lies in documenting the developing public record.

Contemporary archive: Ukraine’s Government Writes to Shell, Accusing It of an Accounting Trick — 22 April 2022.

9. Wednesday, 27 April: Reuters documents the change

The most decisive development came on 27 April 2022.

Reuters journalists Ron Bousso and Rowena Edwards reported that Shell had tightened its purchasing restrictions.

The company would no longer accept refined petroleum products containing Russian-origin material, including blended fuels.

Reuters had examined a bid placed by Shell for a cargo of jet fuel through the Platts trading process.

The new conditions prohibited Russian-origin products.

They also prohibited products blended with material produced in Russia.

The conditions extended to the transportation route, excluding arrangements involving Russian transit.

This was materially different from the earlier threshold.

Under the previous conditions described by Bloomberg, a cargo containing less than 50% Russian material could satisfy the origin requirement.

Under the new conditions reported by Reuters, Russian-origin material was excluded regardless of its proportion in the blend.

A Shell spokesperson confirmed that the trading terms had changed.

The company described the amendment as another stage in removing Russian oil and gas from its supply chain.

Reuters also noted an important limitation.

The revised refined-product conditions did not themselves alter the separate arrangements concerning Russian crude oil, which Shell was continuing to phase out.

This distinction is essential.

Shell had tightened its purchasing rules for blended refined products. That did not mean every remaining Russian crude-oil contract had been extinguished.

The article was published by Reuters on 27 April and appeared in several international publications.

RoyalDutchShellPlc.com preserved the report that evening. Investing.com UK

10. What the new trading conditions actually established

The revised language was more demanding than the earlier contractual definition.

It did not merely require a non-Russian origin designation.

It addressed the possibility that a product had been blended with material originating in Russia.

It also covered aspects of the transportation route.

These conditions were significant because they moved beyond a simple percentage threshold.

But the wording should still be interpreted carefully.

The Reuters report establishes that the new conditions appeared in a particular trading bid.

It establishes that a Shell spokesperson confirmed the tightening of the company’s purchasing terms.

It does not establish the contents of every subsequent Shell trading contract.

Nor does it prove that every supplier could independently verify the complete origin of every component in every product.

Contractual restrictions and physical traceability are different questions.

A contract may require a seller to certify that a product contains no Russian-origin material.

Whether that certification is reliable depends upon the seller’s records and the wider supply chain.

For blended petroleum products, the relevant evidence could include certificates of origin, bills of lading, refinery records, storage-terminal records and contractual declarations.

Some of those documents may be difficult to reconcile where material has passed through several intermediaries.

Shell’s revised terms therefore represented a more restrictive purchasing policy.

They did not, by themselves, establish that the global petroleum supply chain had become fully traceable.

This distinction would become particularly important in the company’s subsequent public comments.

11. Was the Latvian blend a sanctions loophole?

The expression sanctions loophole appeared frequently in reporting about Russian petroleum.

But it requires legal precision.

On 27 April 2022, the European Union had not yet adopted the comprehensive Russian oil-import restrictions included in its sixth sanctions package.

Those measures were announced on 3 June 2022.

The EU subsequently introduced phased prohibitions concerning seaborne Russian crude oil and refined petroleum products.

The restrictions included specified transitional periods and exceptions.

The United Kingdom had announced on 8 March that it would phase out Russian oil imports by the end of 2022.

The principal UK prohibition on importing Russian oil and oil products subsequently took effect on 5 December 2022.

The legal environment in April was therefore different from that which developed later.

Companies were already subject to sanctions affecting particular Russian individuals, institutions and activities.

But Russian petroleum products were not universally prohibited across all relevant European markets.

A company could face substantial public criticism for purchasing Russian-origin petroleum even when a particular purchase was not prohibited by the sanctions then applicable.

That is the distinction at the centre of this controversy.

Shell’s 50% definition was a contractual purchasing condition.

It should not be represented as a statutory exemption permitting violations of sanctions.

Nor should later sanctions restrictions be applied retrospectively to a transaction from March or April 2022.

There is another relevant distinction.

Customs rules concerning the origin of products can involve questions about processing and substantial transformation.

Simply mixing products and refining crude oil are not necessarily equivalent for origin purposes.

The applicable rules depend upon the legislation and the circumstances of the particular product.

The 49.99% threshold should therefore not be confused with a universal legal test of whether Russian petroleum had ceased to be Russian.

Official sources: UK Government — Phase-out Announcement, 8 March 2022; Council of the European Union — Sixth Sanctions Package, 3 June 2022; and UK Government — Russian Oil Import Ban and Implementation Guidance.

12. The wider industry: Shell was not operating in isolation

The problem of Russian-origin petroleum was not confined to Shell.

International fuel markets relied upon extensive networks of producers, refiners, traders, terminals and transport companies.

Europe had been a major importer of Russian crude and refined products before the invasion.

According to Eurostat data cited by Reuters, Russia supplied slightly more than a quarter of the European Union’s oil imports in 2020.

Diesel and jet fuel were particularly important.

As companies began restricting Russian purchases, alternative supplies had to be obtained from other producers and refineries.

That involved shipping capacity, refinery compatibility, storage and financing.

In these circumstances, the origin of blended petroleum products became increasingly important.

Reuters reported on 27 April that TotalEnergies, Repsol and BP had adopted restrictions excluding refined products containing Russian material.

Shell’s revised conditions therefore brought its publicly reported purchasing requirements closer to those of several major competitors.

But it would be misleading to assume that every international energy company adopted identical policies at the same time.

Companies had different contractual obligations and geographical operations.

Their exposure to Russian crude, refined products, LNG and pipeline gas also differed.

Some retained long-term contracts while discontinuing new purchases.

Others were primarily affected by investments in producing assets.

The wider industry context helps explain why removing Russian-origin petroleum from international markets proved difficult.

It does not determine whether Shell’s earlier contractual definition was commercially or ethically appropriate.

That is a separate question. euronews

13. The UK import figures reveal another difficulty

Official UK trade statistics provide useful retrospective context.

On 24 August 2022, the Office for National Statistics reported that the United Kingdom had imported no fuels from Russia during June.

It was the first month without such recorded imports since the relevant statistical series began in January 1997.

The figures showed a dramatic reduction following Russia’s invasion.

Before the war, Russia had supplied approximately 24.1% of the UK’s refined-oil imports in 2021.

The ONS attributed the subsequent decline to sanctions and companies voluntarily seeking alternative suppliers.

This was an important development.

It demonstrated that direct recorded fuel imports from Russia had fallen dramatically.

However, the figures should not be interpreted as proof that every petroleum product consumed in Britain was entirely free of Russian-origin material.

Trade statistics depend upon the classifications and origin information used in recording international transactions.

A product refined in another country may be recorded differently from the Russian crude oil used as an input.

The issue becomes particularly complicated when the original feedstock has passed through a foreign refinery.

The ONS statistics therefore establish the reduction in recorded imports from Russia.

They do not provide complete molecular traceability of the entire British petroleum supply chain.

That limitation is important when assessing the longer-term effectiveness of policies intended to exclude Russian-origin hydrocarbons. Office for National Statistics

14. The unresolved question: What was actually purchased?

This investigation has identified a clear sequence of documentary evidence.

Shell publicly committed itself to withdrawing from Russian hydrocarbons.

Its purchasing conditions subsequently attracted criticism because they permitted certain blended refined products containing less than 50% Russian material.

Ukraine’s government challenged those conditions.

Shell disputed allegations that it was deliberately purchasing Russian products for blending and resale under a non-Russian designation.

Reuters then documented a change to more restrictive trading terms.

But several potentially important records remain unavailable.

The complete earlier contractual conditions would help establish precisely how Shell defined Russian-origin material across different products and transactions.

The relevant trading bids would help clarify the circumstances in which those terms were used.

Cargo-level records would establish whether purchases were completed, what products were delivered and what their actual compositions were.

Shipping and storage-terminal records could identify the origin and movements of specific quantities of material.

Internal Shell correspondence could explain why the earlier threshold was adopted and what prompted its subsequent removal.

Without those records, it would be premature to claim that Shell deliberately engineered particular shipments to evade sanctions.

It would also be premature to assert that no products containing Russian-origin material were acquired under the earlier conditions.

The available evidence supports a narrower and more reliable conclusion.

Shell’s publicly reported trading conditions permitted certain Russian-containing blends after its March withdrawal announcement. The company subsequently tightened those conditions following public scrutiny and criticism.

That is an important finding.

It does not require speculation about transactions that have not been independently established.

DOCUMENTARY FINDINGS Established facts

Shell announced its intention to withdraw from Russian hydrocarbons on 8 March 2022.

The company immediately committed to ending spot purchases of Russian crude while acknowledging that withdrawal from other products and contracts would take longer.

Bloomberg reported on 8 April that Shell’s trading conditions could classify blended petroleum products containing less than 50% Russian-origin material as non-Russian.

A Shell bid for ultra-low-sulphur diesel dated 30 March was subsequently identified in Bloomberg reporting as using the relevant origin definition.

The expression Latvian blend became associated with the practice of mixing Russian petroleum products with material from other countries.

Latvian authorities and media examined questions arising from the reporting.

Operators associated with Ventspils disputed their involvement in the alleged activities.

Oleg Ustenko, an adviser to Ukraine’s president, challenged Shell’s purchasing conditions in a letter dated 13 April.

Shell disputed the allegation that it was purchasing Russian products for deliberate blending and resale as non-Russian.

On 27 April, Reuters reported that Shell had tightened its trading conditions to exclude refined products containing Russian-origin material.

Reuters examined a jet-fuel trading bid containing the revised conditions.

A Shell spokesperson confirmed the change.

The revised terms did not automatically terminate every remaining Russian crude-oil contract.

The relevant comprehensive EU oil restrictions were introduced after the April controversy.

Matters requiring qualification

The 49.99% figure illustrates the contractual threshold. It is not independently established as the composition of every cargo purchased by Shell.

A trading bid is evidence of an offer or purchasing condition, not necessarily a completed transaction.

The available documents do not establish that Shell itself physically blended Russian petroleum with other products.

They do not establish that all cargoes described as Latvian blends originated in Latvia.

The original Ukrainian letter has been reported by reputable contemporary sources, but the complete signed document has not been independently examined for this instalment.

The complete original Shell contracts and associated cargo documentation have not been obtained.

Legal position

No court judgment specifically determining Shell’s liability in relation to the April 2022 blending arrangements has been identified in the materials examined.

The documentary evidence does not establish that Shell violated sanctions through the reported contractual definition.

The commercial and ethical controversy must be distinguished from the legal status of particular transactions.

A private 50% origin threshold was not a universal exemption under sanctions law.

Not established

The available evidence does not prove that Shell deliberately designed the blending arrangements to circumvent sanctions.

It does not establish that particular Shell executives ordered traders to conceal Russian petroleum.

It does not establish the quantity or value of Russian-origin products actually acquired under the disputed conditions.

It does not establish that Shell knowingly submitted false declarations of origin.

Nor does it establish that the change announced on 27 April immediately eliminated every indirect Russian-origin component from the company’s global supply chain.

EDITORIAL COMMENTARY The difference between leaving Russia and removing Russia from the supply chain

This episode exposes an important distinction between a company’s public commitments and the operational systems through which those commitments must be implemented.

Shell’s March announcement was an expression of corporate intention.

Its trading conditions governed the circumstances in which commercial transactions could proceed.

The two were related, but they were not identical.

The company intended to withdraw from Russian hydrocarbons.

Its earlier purchasing terms nevertheless permitted some refined products containing Russian-origin material.

That was sufficient to generate substantial criticism, even without proof that Shell had intentionally purchased specific cargoes to conceal their origin.

The Ukrainian government’s objection was understandable within the circumstances of the war.

Ukraine was seeking to reduce Russian energy revenues.

From that perspective, purchasing a product containing substantial quantities of Russian petroleum could still indirectly support Russian exports, regardless of how the finished product was classified.

Shell’s response reflected another concern.

The company was attempting to disentangle itself from complex supply chains while maintaining fuel availability for customers.

That concern also had a legitimate commercial basis.

European dependence upon Russian petroleum could not be eliminated merely by issuing a corporate announcement.

Refineries required feedstocks.

Traders were subject to existing contracts.

Customers continued to need fuel.

The difficulty was real.

But so was the reputational risk.

A company that publicly declares an intention to stop dealing in Russian hydrocarbons creates expectations about its subsequent conduct.

Those expectations extend beyond the narrow wording of individual announcements.

If commercial purchasing conditions permit substantial Russian content, the company must be prepared to explain why those arrangements remain consistent with its commitment.

In Shell’s case, that explanation was challenged.

The company subsequently tightened its trading requirements.

The documentary record does not establish whether criticism was the sole reason for that decision.

But the change is clear.

The importance of the original documents

The episode also demonstrates why contemporaneous records matter.

The public statements explain Shell’s declared policy.

Bloomberg’s reporting identifies the earlier contractual threshold.

The Ukrainian letter records the government’s objections, as reported by contemporary journalists.

Shell’s response explains what the company disputed.

Reuters’ investigation establishes the subsequent tightening of the purchasing conditions.

Official government records clarify the legal environment.

Each source answers a different question.

None should be made to answer questions beyond its evidential scope.

Most importantly, the Reuters report of 27 April should not be treated as proof that Shell had previously committed a sanctions offence.

It is evidence that Shell changed its trading terms.

Equally, the company’s statement that it was acting lawfully does not resolve every question about whether the earlier arrangements were consistent with the spirit of its withdrawal commitment.

Legal compliance and corporate accountability are related but distinct considerations.

A conclusion supported by the evidence

The March apology did not instantly remove Russian-origin petroleum from every part of Shell’s international trading arrangements.

By April, the company’s purchasing terms still permitted certain blended refined products containing less than 50% Russian material.

Those terms attracted criticism.

Shell disputed the suggestion that it was deliberately purchasing Russian products for disguised resale.

The company then changed its purchasing requirements.

This is the central documentary finding: Shell’s withdrawal from Russian energy involved successive revisions to its commercial practices, rather than a single immediate break.

That conclusion is supported by Shell’s statements and contemporaneous reporting.

It requires no allegation of secret criminal conduct.

But the controversy also points towards a more difficult problem.

Even when a company excludes products blended directly with Russian petroleum, what happens when Russian crude is refined in another country before the resulting diesel or jet fuel enters international markets?

That question cannot be answered simply by examining the percentage of Russian material in a blended cargo.

It concerns the fundamental ability of international commodity markets to trace petroleum back to its original source.

And Shell’s own chief executive would soon acknowledge just how difficult that could be.

PRINCIPAL SOURCES

1. Shell plc — Shell Announces Intent to Withdraw From Russian Oil and Gas, 8 March 2022

The authenticated corporate announcement establishing the distinction between the immediate halt to Russian crude spot purchases and the phased withdrawal from other Russian hydrocarbons.

Read Shell’s original announcement

2. Bloomberg Opinion — Javier Blas, The Backdoor That Keeps Russian Oil Flowing Into Europe, 8 April 2022

The contemporary investigation describing the 49.99% contractual threshold and the trading-market expression Latvian blend. This is an attributed Bloomberg analysis, not an independent judicial finding.

Read the Bloomberg investigation

3. Latvian Public Media — Investigation of Reports Concerning the Latvian Blend, 12 April 2022

Reports Latvian authorities’ interest in the allegations and records denials from operators associated with the Ventspils petroleum terminals.

Read the original Latvian report

4. Bloomberg — Laura Hurst, Ukraine Criticizes Shell’s Rules on Russian Fuel Purchases, 22 April 2022

Documents the letter dated 13 April from Oleg Ustenko, the March 30 trading-bid conditions and Shell’s response to the Ukrainian government’s allegations.

Read the Bloomberg report reproduced by gCaptain

5. RoyalDutchShellPlc.com — Ukraine’s Government Writes to Shell, Accusing It of an Accounting Trick, 22 April 2022

The contemporary Donovan–Shell archive preserves the City A.M. account of the dispute and Shell’s denial.

Read the original archive entry

6. Reuters — Ron Bousso and Rowena Edwards, Shell Tightens Restrictions on Russian Oil Buying, 27 April 2022

The central contemporary report establishing the revised trading conditions, the Platts jet-fuel bid and Shell’s confirmation of the change.

Read the Reuters report

7. RoyalDutchShellPlc.com — Shell Tightens Restrictions on Russian Oil Buying, 27 April 2022

The contemporary Donovan–Shell archive’s complete reproduction of the Reuters account.

Read the original archive publication

8. UK Government — UK to Phase Out Russian Oil Imports, 8 March 2022

The official announcement establishing the initial British policy of ending Russian oil imports by the end of 2022.

Read the UK government statement

9. Council of the European Union — Sixth Sanctions Package, 3 June 2022

The official record of the EU’s subsequent Russian oil-import restrictions and their phased implementation.

Read the Council announcement

10. Office for National Statistics — The Impact of Sanctions on UK Trade With Russia, 24 August 2022

Official statistics documenting the reduction in recorded Russian fuel imports and providing context concerning Britain’s former dependence on Russian refined petroleum.

Read the ONS analysis

Documentary disclaimer

This instalment relies upon authenticated Shell corporate statements, contemporary Bloomberg and Reuters reporting, official UK and European Union records, Latvian public-media reporting and contemporary material preserved by RoyalDutchShellPlc.com.

The earlier Shell trading conditions are documented through published reporting concerning observed trading bids. The complete original contracts and cargo-level transaction records have not been independently examined.

The correspondence from Ukrainian presidential adviser Oleg Ustenko is identified through contemporaneous reporting. The original signed letter has not been independently obtained.

The Ukrainian government’s allegations concerning an accounting trick are reported as allegations.

Shell’s contemporaneous denials and explanations are included.

The existence of contractual terms permitting some Russian-origin material is distinguished from proof that particular cargoes were delivered under those terms.

No allegation is made that Shell deliberately falsified certificates of origin, knowingly breached sanctions or committed a criminal offence through the reported arrangements.

The term Latvian blend is identified as contemporary commodity-market terminology. It does not constitute proof of misconduct by any specific Latvian company or terminal operator.

The article distinguishes the contractual purchasing restrictions adopted voluntarily by Shell from sanctions imposed by governments.

Later sanctions legislation is not applied retrospectively.

The revised trading conditions announced on 27 April 2022 are not presented as evidence that every existing contractual relationship involving Russian energy was immediately terminated.

Editorial commentary concerning the consistency of Shell’s public commitments and commercial practices is separately identified.

Factual corrections, additional primary documents and responses from Shell or other interested parties are welcome.

The website’s general disclaimer also applies.

NEXT IN THE SHELL LEAKS FILES SLF-2007-105 — The Sakhalin Papers XCV: The Molecule Problem — Russian Crude Refined Abroad and the Limits of Shell’s Clean Break

On 27 April 2022, Shell tightened its trading conditions to exclude refined petroleum products containing Russian-origin material.

It appeared to close the most controversial aspect of the Latvian blend arrangements.

But eight days later, on 5 May, Shell chief executive Ben van Beurden publicly explained a far more difficult problem.

There was no comprehensive international system capable of tracing every petroleum product back to the country in which its original crude oil had been extracted.

The distinction mattered.

Russian crude could be exported to a country outside Europe.

A refinery in that country could process it into diesel, petrol or jet fuel.

The resulting petroleum products could then enter international markets under the origin rules applicable to the refined goods.

Van Beurden used the example of diesel produced at an Indian refinery from Russian crude.

The product could be treated as Indian diesel for the purposes he was discussing.

His comments were reported by Reuters and S&P Global Commodity Insights.

They raised an uncomfortable question.

How could Shell promise to eliminate Russian-origin petroleum from its supply chain when its own chief executive acknowledged that the global system could not reliably trace every refined product back to its original crude-oil source?

The answer requires examining the difference between physical origin, customs origin, contractual representations and the practical limits of commodity-market traceability.

It also requires distinguishing an unavoidable limitation of international refining from deliberate sanctions evasion.

The next instalment will examine Shell’s 5 May 2022 statements, the contemporaneous industry reporting and the regulatory framework governing petroleum refined outside Russia.

The question is not whether Shell changed its purchasing rules.

That is established.

The question is whether those rules could ever guarantee what the company’s public commitments appeared to promise.

The Sakhalin Papers continue.

Documentary starting point for the next investigation: S&P Global Commodity Insights — Shell Flags Industry Hurdles to Blocking All Russian Imports Into the EU, 5 May 2022.

THE SHELL LEAKS FILES — 31 OCTOBER 2026 was first posted on October 31, 2026 at 8:55 pm.
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Comment from “An Old EP Hand” on the article: Shell’s $6.4 Billion Pension Bombshell: SEC Disclosure Reveals Major Accounting Loss Expected as Dutch Retirement Scheme Changes

Hello John

I had not looked at your site for a while when someone sent me your piece on the SSPF.

I distributed that to several old colleagues. Great appreciation. This whole deal is murky and stinks to high heaven. We should have closed the fund and not chosen for ‘invaren’.

But the politicians and evil HR staff forced/bamboozled the staffcouncil to agree. This whole deal is sold as transparant but it is as intransparant as can be.

Delta Lloyd and IBM have chosen to close and not go for invaren.

Unilever and Dow (and others) also chose not to go for invaren.

It all started when a caretaker government (had fallen and elections were planned) signed a few days before going home the new pension law against advice of many genuine experts. In the law it is fixed that individuals have no rights anymore. So we are neutralised. As a thank you the PM became secretary of the NATO and the minister who signed the law became mayor of Rotterdam. You scratch my back, I scratch your back…

Blackrock  and other xxxxxxxxx will now run many pensionfunds.

And this choice for Blackrock by Shell after our own organisation (Shell Asset Management) had done a great job for many years. It just stank.

So your piece was (as usual) very timely. But I fear we can do nothing anymore. The rich dutch pensionfunds will be robbed empty and given to the ‘poor’ countries like France, Italy, Greece and others.

Shell’s $6.4 Billion Pension Bombshell: “This whole deal is murky and stinks to high heaven” was first posted on October 31, 2026 at 8:00 pm.
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Shell’s latest financial statements reveal a remarkable accounting consequence of the Middle East conflict. While the oil giant reports extraordinary profits, soaring tanker freight rates have triggered billions of dollars in additional shipping-lease liabilities. The figures are non-cash adjustments, not realised losses, but they expose another dimension of Shell’s vulnerability to geopolitical disruption.

By John Donovan — 31 October 2026

Shell plc’s spectacular third-quarter profits have attracted considerable attention.

The company reported adjusted earnings of $10.814 billion on 29 October 2026, almost double the amount recorded in the corresponding quarter last year.

The financial results have already generated controversy over the extent to which major oil producers are benefiting from the Iran war and the resulting disruption to international energy markets.

But another significant disclosure, buried in the accompanying financial statements, deserves closer examination.

Shell reports that changes in shipping-market conditions resulted in $5.4 billion of non-cash increases in the variable component of its shipping leases during the third quarter.

And the figure becomes even more striking when the reporting period is extended.

During the first nine months of 2026, Shell recorded $7.684 billion in upward adjustments to shipping-lease liabilitiesas a consequence of rising freight-rate indices associated with the Middle East conflict.

These are extraordinary figures.

They are not, however, equivalent to billions of dollars in immediate cash losses.

Understanding that distinction is essential to interpreting what Shell has disclosed.

What Shell actually revealed

The relevant information appears in Shell’s third-quarter financial report, published on 29 October 2026 and included in its US regulatory reporting.

A footnote on page 2 explains that the company’s quarterly lease additions include $5.4 billion in non-cash increases associated with the variable component of shipping leases.

A more detailed explanation appears in Note 7, under the heading Debt, on page 33.

Shell states that certain vessel leases involve payments linked to market indices.

Under International Financial Reporting Standard IFRS 16, the company is required to remeasure the associated lease liabilities using applicable spot rates.

During the first nine months of 2026, the Middle East conflict caused substantial increases in the underlying freight-rate indices.

The result was a $7.684 billion increase in the relevant lease liabilities compared with their measurement at 31 December 2025.

Shell also recognised corresponding adjustments to the associated right-of-use assets in its property, plant and equipment.

The company cautions that the spot rates used in these calculations may not reflect the payments ultimately made under its long-term shipping arrangements.

That warning is particularly important.

A sharp rise in a freight-rate index can produce a large accounting adjustment without necessarily producing an equivalent increase in the future cash payments actually required.

Nevertheless, the figures reveal the scale of Shell’s exposure to exceptionally volatile shipping markets.

Why the Iran conflict matters

Oil and liquefied natural gas are transported through international shipping networks that can be severely affected by military conflict, sanctions, port restrictions and changing security conditions.

The Middle East occupies an especially important position in those networks.

The Strait of Hormuz, connecting the Persian Gulf with the Gulf of Oman, is one of the world’s most strategically significant energy transport routes.

Disruption affecting shipping in the region can increase insurance costs, alter vessel availability, lengthen voyages and raise freight rates.

For a company with Shell’s international trading and LNG operations, such changes can have substantial consequences.

Shell does not merely produce and sell hydrocarbons.

It also operates within a vast international system of commodity trading, maritime transport, storage and supply contracts.

Consequently, the commercial impact of geopolitical instability can extend far beyond changes in the market prices of oil and gas.

The latest financial statements demonstrate that shipping costs and related accounting obligations can also become major sources of volatility.

Importantly, Shell expressly links the increased freight-rate indices underlying its lease adjustments to the Middle East conflict.

That connection is not an allegation from an environmental organisation or an outside commentator.

It is the company’s own explanation in its published financial statements.

How can a lease liability increase by billions without a cash loss?

This is the central accounting question.

Under IFRS 16, companies generally recognise liabilities representing the present value of qualifying future lease payments.

They also recognise corresponding right-of-use assets reflecting their contractual rights to use the leased equipment or property.

In Shell’s case, some of these arrangements concern vessels whose lease payments are linked to shipping-market indices.

When the relevant indices change, accounting rules may require the recognised lease liabilities to be recalculated.

If the applicable market index rises dramatically, the present value of future payments used in the accounting calculation can increase substantially.

A corresponding adjustment is generally made to the right-of-use asset.

The result is that both the liability and the recognised asset can increase even though no immediate cash transaction has occurred.

Shell’s own figures illustrate the effect.

At 30 September 2026, the company’s total lease liabilities stood at $34.147 billion, compared with $28.933 billion at 31 December 2025.

This net balance-sheet increase is smaller than the $7.684 billion index-related adjustment because other movements, including lease payments and changes elsewhere in the lease portfolio, also affect the overall balance.

The $7.684 billion figure is therefore not the total increase in Shell’s lease liabilities.

Nor should it be added to the $5.4 billion quarterly adjustment as though they represent separate losses.

The quarterly figure forms part of the broader nine-month development.

That distinction is essential to accurate reporting.

The accounting consequences do not end there

Shell explains that the remeasurement of its vessel leases creates a corresponding increase in right-of-use assets.

Those assets are then depreciated prospectively over the remaining lease terms.

This means the adjustment can influence future reported depreciation expenses.

However, the ultimate economic impact will depend partly on how the relevant shipping indices evolve and what payments become due under the contracts.

If market conditions normalise, subsequent accounting measurements may change.

It would therefore be misleading to describe the entire $7.684 billion as a permanent realised financial loss.

Equally, it would be wrong to dismiss the disclosure as meaningless simply because it is non-cash.

The adjustment reflects real contractual exposure to volatile market conditions, measured according to the applicable accounting framework.

Shareholders are entitled to understand that exposure and the assumptions used to calculate it.

Profits on one side, shipping volatility on the other

The shipping disclosure presents a striking contrast with Shell’s headline financial performance.

For the third quarter of 2026, Shell reported:

Financial measure Q3 2026 Adjusted earnings $10.814 billion Income attributable to shareholders $12.057 billion Cash flow from operations $21.043 billion Free cash flow $16.322 billion Net debt at quarter-end $39.733 billion New share-buyback programme $5 billion

Shell’s performance was supported by strong refining margins and substantial cash generation.

But the Middle East conflict has not simply created favourable conditions.

It has also disrupted energy production, affected shipping markets and increased financial volatility.

Shell’s figures show how the same geopolitical environment can produce very different effects across the business.

Higher hydrocarbon prices and refining margins may support earnings, while increased shipping costs and contractual exposures create additional pressures.

The net consequences cannot be determined from any single accounting adjustment.

That is why the shipping disclosure matters.

It provides a fuller picture of the risks accompanying Shell’s extraordinary profitability.

The link with our investigation into executive rewards

On 30 October, this website published an investigation examining Greenpeace’s estimate that Shell chief executive Wael Sawan had experienced a £4.7 million increase in the value of his shareholding during the Iran conflict.

That article also documented Sawan’s earlier disposal of 40,000 Shell shares for approximately €1.49 million, using Shell’s own regulatory notification.

The shipping disclosure adds another important dimension to the financial story.

It demonstrates why the consequences of geopolitical conflict cannot simply be categorised as a windfall for every part of an oil company’s operations.

Shareholder valuations, realised executive transactions, operating earnings, future shipping obligations and non-cash accounting adjustments are different financial measures.

Each must be assessed on its own terms.

The company’s profitability is real.

So is the volatility reflected in its shipping-lease calculations.

The challenge is to understand how those developments interact without overstating the evidence.

What about Shell’s exposure to LNG shipping?

Shipping is particularly important to Shell’s Integrated Gas business.

Liquefied natural gas must be transported using specialised vessels and supporting infrastructure.

Shell’s global LNG activities involve production, trading, transport and customer supply commitments across multiple regions.

The company has also been expanding its exposure to natural gas through major investments.

In September 2026, Shell completed its acquisition of ARC Resources, strengthening its Canadian gas portfolio.

During the same month, the company announced a final investment decision on LNG Canada Phase 2.

That project is intended to double LNG Canada’s production capacity from 14 million tonnes annually to 28 million tonnes.

These developments underscore the strategic importance of natural gas and LNG within Shell’s future portfolio.

However, Shell’s quarterly disclosure does not provide a sufficiently detailed breakdown to attribute the $7.684 billion shipping-lease adjustment exclusively to LNG carriers rather than other qualifying vessel leases.

Such a conclusion would require additional information.

What is clear is that international shipping arrangements represent an important element of Shell’s commercial and accounting exposure.

The historical perspective: energy transport and geopolitical risk

For readers of the Independent Shell Archive and The Shell Leaks Files, the latest disclosure belongs to a much longer history.

Shell’s development into a major international energy company has always depended on access to resources and the ability to transport those resources across borders.

Shipping routes, political instability, government intervention and international disputes have repeatedly influenced the company’s operations.

The historical archive documents numerous examples of Shell confronting political and commercial risk.

The Sakhalin-2 project provides one particularly significant example of the relationship between major energy investments and geopolitical power.

That history should not be confused with the present circumstances.

The 2026 shipping-lease adjustments are accounting consequences arising from freight-market conditions, not evidence of wrongdoing or a repetition of the Sakhalin controversy.

Nevertheless, both illustrate a broader reality.

International energy companies are profoundly exposed to political developments beyond their direct control.

Their financial performance cannot be understood solely through production volumes, commodity prices or headline profits.

Transport infrastructure and access to international markets are equally important.

Questions shareholders should ask

Shell’s disclosure raises several legitimate questions.

1. Which shipping arrangements are principally responsible?

What proportion of the remeasurement relates to LNG carriers, oil tankers and other vessels?

2. How long do the affected leases run?

Long-term contracts indexed to unusually high spot rates could produce accounting measurements that differ materially from eventual cash payments.

3. What is the actual cash exposure?

How does Shell expect the increase in freight-rate indices to affect payments over the remaining contractual periods?

4. How sensitive are the reported liabilities to lower shipping rates?

Would a return towards earlier freight-market conditions produce substantial downward remeasurement?

5. What are the implications for reported depreciation?

How will the adjusted right-of-use assets influence future accounting expenses?

6. How does Shell manage geopolitical shipping risk?

What contractual, operational and financial arrangements are used to limit exposure to sudden disruption?

These questions do not imply that Shell has breached accounting rules or mismanaged its shipping contracts.

They arise from the magnitude of the adjustment and the importance of the underlying exposures.

A revealing footnote in a remarkable quarter

Shell’s third-quarter financial statements contain several substantial disclosures.

They include a $2.116 billion impairment relating to a European biogas asset, an impairment reversal of $1.787 billion associated with an Integrated Gas asset, and a projected $6.4 billion non-cash charge relating to the restructuring of the company’s Dutch pension arrangements.

All three have already been examined in our recent investigations.

The shipping-lease disclosure provides another example of how significant financial developments can appear within the detailed notes rather than the headline announcements.

The $5.4 billion quarterly figure is substantial.

The $7.684 billion nine-month adjustment is even more striking.

But neither should be presented as an immediate cash loss.

The company’s own explanation establishes that the figures result from the remeasurement of index-linked vessel leases under IFRS 16, with corresponding asset adjustments.

It also acknowledges that prevailing spot rates may not accurately represent eventual payments.

That qualification is vital.

Nevertheless, the disclosure illuminates a significant source of financial volatility at a time when the global energy industry is experiencing exceptional geopolitical disruption.

Conclusion: the other side of Shell’s Iran war results

Shell’s latest financial performance demonstrates the extraordinary earning power of a global energy company operating during a period of sharply changing commodity markets.

Its shipping disclosures demonstrate something equally important.

The same international conflict associated with high refining margins and substantial profits can also produce multibillion-dollar changes in contractual liabilities.

Those changes may be accounting adjustments rather than immediate cash losses, but they are not irrelevant.

They reveal financial exposures that shareholders should understand.

The important story is not that Shell has suddenly lost $7.684 billion in cash. It has not reported such a loss.

The story is that the Iran conflict has driven shipping-market conditions severe enough to produce an enormous remeasurement of the company’s vessel-lease obligations.

For an international energy business whose operations depend on maritime transport, that is a significant disclosure.

And it is precisely the kind of information that deserves careful preservation in the historical record.

Principal sources

1. Shell plc — Third Quarter 2026 and Nine Months Unaudited Results, 29 October 2026

Official Shell quarterly financial statements

The primary source for the financial figures discussed in this article.

Of particular relevance are page 2, footnote 4, concerning the $5.4 billion non-cash shipping-lease increase, and page 33, Note 7, concerning the $7.684 billion remeasurement of index-linked vessel leases.

2. US Securities and Exchange Commission

SEC EDGAR — Shell plc company filings

Regulatory reporting archive. The third-quarter report was supplied as part of Shell’s 29 October 2026 Form 6-K filing.

3. IFRS Foundation — IFRS 16 Leases

Official IFRS 16 accounting standard overview

Background on the accounting rules governing lease liabilities and right-of-use assets.

4. Previous Independent Shell Archive reporting

Shell’s $10.8 Billion Profit Bonanza: A $2.1 Billion Biogas Write-Down as LNG Canada Gains $1.8 Billion in Value — 29 October 2026

Shell’s $6.4 Billion Pension Bombshell — 30 October 2026

Shell CEO’s Shares Gain £4.7 Million During Iran War — 30 October 2026

Editorial note: This article is based primarily on Shell plc’s third-quarter financial disclosures released on 29 October 2026. The $5.4 billion quarterly adjustment and $7.684 billion nine-month adjustment concern overlapping periods and must not be added together. Both relate to non-cash lease accounting adjustments rather than realised losses of equivalent amounts. No accounting irregularity, regulatory breach or misconduct is alleged. Shell plc is invited to provide additional explanations or factual corrections, which will be considered for publication.

Shell’s Iran War Windfall Has Another Side: SEC Filing Reveals $5.4 Billion Shipping-Lease Shock was first posted on October 31, 2026 at 11:24 am.
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One London council wants Shell to help pay for climate protection. Another is inviting the oil giant to move its headquarters across the Thames. The extraordinary exchange has revived memories of historic Shell-Mex House on the Strand — a building with its own place in the history of the Donovan family’s dealings with Shell.

By John Donovan — 31 October 2026

Shell plc has found itself at the centre of an unusual disagreement between two London local authorities.

In Lambeth, where Shell maintains its London headquarters on the South Bank, the Green Party-led council has publicly challenged the oil giant to contribute towards the costs of protecting local residents from climate change.

Across the River Thames, Westminster City Council’s deputy leader has responded with a rather different proposition.

If Shell feels unwelcome in Lambeth, Westminster would be delighted to have it back.

The invitation comes from Councillor Timothy Barnes, Deputy Leader of Westminster City Council and Cabinet Member for Growth and Planning, in an open letter addressed to Shell chief executive Wael Sawan.

Published by The Critic on 30 October 2026, the letter offers to assist Shell with relocating to Westminster and argues that successful businesses should be welcomed for the employment, investment and economic activity they generate.

The exchange highlights contrasting approaches to corporate responsibility, local government finance and the treatment of major international businesses.

It also revives a fascinating chapter of Shell’s London history.

Lambeth challenges Shell over climate funding

As we reported on 24 October, Lambeth Council has been asking Shell to help finance measures to protect local communities against the effects of climate change.

Deputy council leader Ciara Alleyne featured in a public appeal outside Shell Centre, the company’s London headquarters near Waterloo.

The campaign included an attempted visit to Shell’s offices, although there was no evidence that a meeting had been arranged or that Shell’s senior management had refused a formal invitation to discuss the issue.

Lambeth’s argument is that companies associated with substantial greenhouse gas emissions should contribute to the costs of protecting communities from climate impacts.

Possible initiatives include measures addressing extreme heat and improving local climate resilience.

The council has highlighted Shell’s substantial profitability and its contribution to global emissions.

However, as our earlier investigation explained, the precise amount being requested, the proposed method of calculation and the legal or voluntary basis of any contribution remain important unanswered questions.

Lambeth’s appeal is a political and environmental initiative, not an established tax liability or binding financial obligation.

That distinction is central to the disagreement now emerging.

Westminster enters the argument

Councillor Barnes has taken issue with Lambeth’s approach.

In his open letter to Sawan, he suggests that Westminster would offer Shell a more welcoming business environment.

He argues that companies already contribute to their surrounding communities through employment, supply chains, local expenditure and existing taxation.

In his view, a council should not treat the worldwide commercial activities of a company as creating an additional financial obligation merely because its headquarters happen to be located within the borough.

Barnes acknowledges that businesses should meet their tax obligations and be held accountable for wrongdoing.

He also accepts that environmental costs should be addressed through appropriate legislation and regulation.

His objection concerns what he regards as public pressure for an additional voluntary payment tied to Shell’s geographical presence.

The letter presents Westminster as an attractive alternative location for an international company of Shell’s scale.

Barnes points to the borough’s concentration of major businesses, financial institutions and commercial headquarters.

He also refers to Westminster’s economic output and the substantial business-rate revenues collected within the borough.

His message is unmistakable.

Rather than encouraging Shell to contribute more money to local climate initiatives, Westminster is offering to discuss how the company might bring additional employment and investment into its jurisdiction.

The invitation appears to have been made publicly through The Critic. We have identified no evidence that Shell requested relocation assistance or that formal negotiations have begun.

The remarkable reference to Shell-Mex House

Perhaps the most interesting passage in Barnes’s letter concerns Shell’s historical association with Westminster.

He reminds Sawan of Shell-Mex House on the Strand, overlooking the Thames.

It is a particularly appropriate reference.

The immense Art Deco building, completed in 1932, became one of the most recognisable symbols of Shell’s corporate presence in London.

With its imposing façade and enormous clock overlooking the river, Shell-Mex House represented the wealth, commercial influence and prestige of the British petroleum industry.

The building was originally associated with Shell-Mex and BP, reflecting the historical relationship between the two companies’ British marketing operations.

It later remained associated with Shell before the company’s presence there came to an end.

Today, the property is known as Eighty Strand.

The building is Grade II listed, and its architectural significance remains recognised independently of the company’s corporate history.

For Westminster’s deputy leader, it provides an obvious reminder that Shell’s connection with the borough extends back generations.

For the present writer, however, Shell-Mex House has an additional personal significance.

A personal recollection: my visits to Shell-Mex House

Long before the present dispute between Lambeth and Westminster, I was a regular and welcome visitor to Shell-Mex House.

During the years when my father, Alfred Donovan, and I were involved in providing promotional ideas and services to Shell through our company, Don Marketing, we developed extensive commercial relationships with the oil group.

Our association with Shell began in the early 1980s and continued for many years.

The subsequent disputes and litigation arising from those relationships are extensively documented in the Donovan–Shell historical archive.

But it is worth remembering that the relationship did not begin in conflict.

For many years, we worked with Shell, presented promotional ideas and enjoyed access to people within its organisation.

My recollections of visiting Shell-Mex House belong to that earlier period.

It is therefore rather striking to see the building return to the headlines through an invitation to Shell to re-establish its presence in Westminster.

The corporate world represented by Shell-Mex House was very different from the Shell of today.

Yet the company’s historical identity remains inseparable from its buildings, commercial relationships and institutional memory.

Those connections deserve preservation alongside the later controversies.

From Shell-Mex House to Shell Centre

Shell’s London corporate history encompasses both sides of the Thames.

Shell-Mex House became a prominent landmark in Westminster, while Shell Centre established the company’s enduring association with the South Bank in Lambeth.

The two buildings reflect different periods in the development of Shell’s British operations.

They also illustrate the company’s substantial physical presence in London over many decades.

Shell Centre, close to the London Eye and Waterloo, became one of the capital’s most recognisable corporate headquarters.

The site has undergone considerable redevelopment, but its association with Shell remains central to its identity.

The present disagreement is therefore not simply about whether one council would welcome a new office tenant.

It concerns a company whose activities have helped shape London’s commercial geography for generations.

That history adds weight to Barnes’s invitation, even if the prospect of a move currently remains hypothetical.

Two councils, two different arguments

The competing positions deserve to be considered on their merits.

Lambeth’s approach emphasises climate responsibility.

Its argument is that local communities face increasingly expensive adaptation requirements and that major fossil-fuel businesses should help meet the associated costs.

Westminster’s approach emphasises investment, employment and the economic contribution of major companies.

Its argument is that councils should encourage successful businesses to establish and expand operations rather than expose them to additional financial demands based simply on where their offices are located.

Neither position automatically resolves the underlying questions.

A council’s request for a voluntary contribution is not necessarily equivalent to imposing a tax.

Equally, the presence of a profitable multinational business within a borough does not automatically establish a legal obligation to finance particular local programmes.

There is also a distinction between a company’s international responsibility for environmental impacts and its relationship with the local authority hosting its headquarters.

Those questions involve policy, taxation, public finance and corporate responsibility.

They cannot be settled solely through competing political statements.

Could Shell really move?

At present, there is no indication that Shell has decided to relocate its London headquarters.

Barnes has made an invitation, not announced an agreement.

A headquarters move by a company of Shell’s size would involve substantial practical and financial considerations.

These might include property arrangements, employee requirements, operational needs and the advantages or disadvantages of remaining at its existing location.

There is no evidence that Shell is undertaking such an assessment in response to Lambeth’s appeal.

Nor should Westminster’s expression of interest be confused with a formal corporate proposal.

For now, the story is principally about the competing messages being directed towards one of Britain’s largest companies.

Nevertheless, an actual response from Shell could turn the exchange into a more substantial development.

What should Shell say?

Shell may prefer not to become involved in a public disagreement between two London councils.

But several legitimate questions arise.

Has Lambeth submitted a formal request for a contribution to its climate resilience programme?

Has Shell responded, or does it intend to discuss the proposal?

Has Westminster approached the company through official channels beyond Barnes’s published letter?

Would Shell consider any change to its London property arrangements?

And what, if any, voluntary contributions does Shell already make towards community or environmental initiatives in the areas where it maintains major offices?

Answers would help distinguish political publicity from substantive commercial developments.

The value of the historical record

For readers of the Independent Shell Archive and The Shell Leaks Files, the story has an importance extending beyond local politics.

The archive documents Shell’s history through corporate records, correspondence, commercial disputes, litigation and contemporary reporting.

But corporate history also includes the people and places associated with a company over time.

Shell-Mex House is one such place.

My own recollection of being a regular visitor provides a small personal connection to that wider history.

The building represents an earlier era when the relationship between Don Marketing and Shell was cooperative, long before the disagreements that would eventually become the subject of extensive legal proceedings and public scrutiny.

Preserving that earlier history is just as important as documenting the disputes that followed.

An accurate historical record should encompass the full development of a relationship, not only its most contentious chapters.

But Could Shell’s Next Destination Be New York?

There is a further irony in the disagreement between Lambeth and Westminster.

While two London councils adopt contrasting positions towards Shell’s presence in the capital, the company has previously considered a far more dramatic change: moving its principal stock-market listing from London to New York.

In February 2023, the Financial Times reported that senior Shell executives had discussed the possibility of relocating both the company’s headquarters and its stock-market listing to the United States.

In April 2024, Reuters reported that Shell chief executive Wael Sawan was considering all available options to address the valuation gap between Shell and American competitors such as ExxonMobil and Chevron.

Former Shell chief executive Ben van Beurden also publicly expressed concern that Shell was undervalued by comparison with its American rivals.

In January 2025, Sawan confirmed that Shell continued to review its options, although a relocation was not then under active discussion.

There is an important distinction between moving a company’s principal stock-market listing and relocating its corporate headquarters. One does not necessarily require the other.

Nor is there presently verified evidence that Shell has decided to pursue either course.

Nevertheless, the history adds an intriguing dimension to Westminster’s invitation.

While Westminster offers Shell a welcome return across the Thames, the more consequential question may ultimately be whether Shell wishes to retain London as the principal financial home of the company at all.

For a business that has already transferred its corporate headquarters from the Netherlands to Britain, the possibility of another major change cannot simply be dismissed.

But until Shell announces a decision, New York remains a previously considered option — not an established destination.

Supporting sources

Reuters, 8 April 2024 — Shell considers options including New York listing

Associated Press, 30 January 2025 — Shell continues reviewing listing options

 

An unexpected invitation across the Thames

The present controversy began with Lambeth asking Shell to contribute towards climate resilience.

It has now produced a public invitation from Westminster to consider moving its headquarters.

The two councils are approaching the same company from markedly different perspectives.

One emphasises environmental costs and corporate responsibility.

The other emphasises economic activity and the benefits of attracting international business.

Whether Shell will respond remains to be seen.

But Barnes’s reference to Shell-Mex House gives the exchange an unexpected historical dimension.

For someone who once visited that building regularly on friendly commercial business, the invitation brings back memories of an earlier Shell.

Half a century of corporate change has not erased Shell’s connection with the Strand.

And it is perhaps fitting that, at a moment when one London council is challenging Shell over its responsibilities, another is reminding the company that it would still be welcome on the opposite side of the river.

Principal sources and further reading

The Critic — 30 October 2026

Shell Would Be Welcome in Westminster — Councillor Timothy Barnes

The original open letter addressed to Shell chief executive Wael Sawan. This is the principal source for Westminster’s invitation and Councillor Barnes’s stated arguments.

Royal Dutch Shell Plc .com — 24 October 2026

Lambeth Puts Shell Under Pressure to Help Pay for Climate Protection

Our earlier report covering Lambeth Council’s climate-funding appeal and the questions surrounding its proposed financial contribution.

Lambeth Council — Official statement, 21 October 2026

Lambeth Council — Official news and announcements

Background on the council’s climate-resilience priorities, including its announced 2027 Climate Emergency Summit.

Historic England

National Heritage List for England — Shell-Mex House, List Entry 1236752

Official heritage record identifying Shell-Mex House as a Grade II listed historic building.

Independent Shell Archive

The Donovan–Shell Historical Archive

Extensive documentary record covering the commercial relationships between Don Marketing and Shell, subsequent disputes, litigation and associated correspondence.

Editorial note: Councillor Timothy Barnes’s invitation is a published political statement, not evidence that Shell intends to relocate. The arguments attributed to Lambeth and Westminster reflect their respective public positions. The personal recollection of visits to Shell-Mex House is the author’s firsthand account and should not be confused with an independently documented corporate record. Shell plc and both councils are invited to provide factual corrections or further comment.

Shell Caught Between Two London Councils: Lambeth Wants Climate Funding, Westminster Offers a Welcome — and a Return to Shell-Mex House was first posted on October 31, 2026 at 11:13 am.
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Greenpeace says four leading oil executives have enjoyed nearly £19 million in increased shareholding value during the Iran conflict. Shell chief executive Wael Sawan accounts for more than £4.7 million of that estimate. But the most revealing evidence comes from Shell’s own regulatory disclosures, which confirm a substantial share disposal in May 2026.

By John Donovan — 30 October 2026

As the Iran conflict continues to disrupt international energy markets, new research by Greenpeace UK has drawn attention to the personal financial benefits experienced by some of the world’s most senior oil executives.

According to the environmental organisation, the shareholdings of four major oil-company chief executives increased in value by nearly £19 million between late February and 28 October 2026.

Among them is Shell plc chief executive Wael Sawan.

Greenpeace estimates that the value of his Shell shareholding increased by more than £4.7 million over the period examined.

Separately, Shell’s own regulatory disclosures confirm that Sawan sold 40,000 ordinary shares on 22 May 2026, generating gross proceeds of €1,486,804.20 — approximately £1.3 million at the exchange rate used in Greenpeace’s reporting.

The timing has attracted attention because the transaction occurred during the Iran conflict and shortly before a reported suggestion by US President Donald Trump that a potential agreement with Iran had largely been negotiated.

There is, however, an important distinction between reporting the timing of a transaction and alleging improper conduct.

Neither Greenpeace’s analysis nor Shell’s regulatory notification establishes that Sawan possessed privileged information, anticipated a diplomatic announcement or breached securities regulations.

What the evidence does establish is a substantial increase in the reported value of executive shareholdings during an extraordinary period for international energy markets.

It also raises legitimate questions about the relationship between geopolitical disruption, shareholder returns and executive remuneration.

Greenpeace identifies nearly £19 million in executive shareholding gains

Greenpeace published its findings on 30 October 2026.

The organisation examined publicly available financial records relating to the chief executives of Shell, TotalEnergies, Harbour Energy and Equinor.

Its calculations cover the period between 27 February and 28 October 2026, using publicly disclosed shareholdings and closing market prices.

The resulting estimates are substantial.

Chief executive Company Estimated increase in shareholding value Patrick Pouyanné TotalEnergies £8.4 million Linda Cook Harbour Energy £4.8 million Wael Sawan Shell £4.7 million Anders Opedal Equinor £1.03 million

The figures are approximate and come from Greenpeace’s analysis, rather than a common accounting measure published by the four companies.

They represent increases in the estimated market value of shareholdings, not necessarily profits realised through sales.

The research does not include executives’ salaries or other benefits.

Greenpeace also reports that the four companies’ shares outperformed their respective domestic stock-market benchmarks during the period.

According to its calculations, Shell shares rose approximately 27%, while the FTSE 100 fell around 2%.

That contrast is central to the organisation’s argument.

While higher energy prices have created financial pressures for consumers and businesses, they have also contributed to stronger valuations for major energy producers.

Shell’s own records confirm Sawan’s €1.49 million share sale

The most important Shell-specific evidence is not Greenpeace’s interpretation.

It is Shell’s own official regulatory notification.

On 22 May 2026, Shell published a Director/PDMR Shareholding announcement identifying a transaction undertaken by its chief executive.

The details were precise:

• Executive: Wael Sawan
• Transaction date: 22 May 2026
• Transaction: Disposal of ordinary Shell shares
• Number sold: 40,000
• Price per share: €37.170105
• Total proceeds: €1,486,804.20
• Transaction location: Amsterdam

The disclosure was made under the applicable UK and European market-abuse disclosure regimes and was also furnished to the US Securities and Exchange Commission through Form 6-K.

These are independently verifiable facts.

The notification establishes the date, volume and value of the transaction.

It does not explain Sawan’s personal reason for selling.

It would therefore be inappropriate to speculate that the sale was motivated by geopolitical developments or expectations about future oil prices.

Sales by company directors are not inherently suspicious.

Executives may dispose of shares for numerous legitimate reasons, including taxation, diversification, personal financial planning or other circumstances.

The regulatory disclosure is nevertheless important because it enables shareholders and the public to examine significant transactions by individuals responsible for managing major listed companies.

The timing highlighted by Greenpeace

Greenpeace places particular emphasis on the fact that Sawan’s sale took place on 22 May 2026.

The organisation notes that this was the day before President Trump reportedly suggested that a potential US–Iran agreement had largely been negotiated.

That proximity is part of Greenpeace’s narrative.

But timing alone does not demonstrate foreknowledge, unusual trading behaviour or wrongdoing.

There is no evidence in the material reviewed that Sawan traded on inside information or acted improperly.

It is also worth remembering that share transactions by senior executives take place within a regulatory framework that includes disclosure obligations and restrictions on dealing.

The proper conclusion is that the transaction merits transparent reporting, not that its timing proves misconduct.

Another Shell disclosure: 82,987 conditional performance shares

An additional regulatory announcement provides important context.

On 21 May 2026, Shell announced that Sawan had received a conditional award of 82,987 performance shares under the Shell Share Plan 2023.

The award was made on 20 May and remained subject to performance conditions determined by the company’s Remuneration Committee and the committee’s discretion.

Shell’s chief financial officer, Sinead Gorman, received a conditional award of 10,964 shares under the same arrangement.

A conditional performance-share award should not be confused with an unconditional payment or an immediate cash benefit.

The shares may become deliverable only if the relevant conditions are satisfied.

Nevertheless, the award illustrates how executive remuneration can create substantial exposure to movements in the company’s share price.

It also provides context for the debate about whether executive reward should reflect improvements in shareholder value arising partly from factors beyond management’s control.

Those factors may include commodity-price changes, exchange-rate movements and geopolitical events.

Shell’s extraordinary third-quarter profits

The Greenpeace investigation arrives immediately after Shell’s announcement of exceptionally strong financial results.

On 29 October 2026, Shell reported:

• Adjusted earnings: $10.814 billion
• Income attributable to shareholders: $12.057 billion
• Operating cash flow: $21.043 billion
• Free cash flow: $16.322 billion
• New share-buyback programme: $5 billion

Adjusted earnings were almost double the $5.432 billion recorded in the corresponding quarter of 2025.

Shell attributed its strong performance to operational delivery in a volatile commodity-price environment, including exceptionally strong refining margins.

The company also acknowledged that the Middle East conflict had disrupted some operations.

Its financial reporting identifies the effects of reduced Qatari production, while LNG Canada contributed additional volumes.

These distinctions matter.

The conflict has not been an unqualified financial benefit to Shell.

It has created both commercial opportunities and operational difficulties.

Nevertheless, the company has demonstrated an ability to generate substantial earnings during a period of major international disruption.

The connection between geopolitical events, commodity prices and corporate profits therefore deserves serious examination.

A £4.7 million increase is not the same as £4.7 million received

The distinction between unrealised shareholding appreciation and money received from a sale is essential.

Greenpeace’s estimate that Sawan’s shares gained more than £4.7 million in value does not mean that he received that amount in cash.

The estimated gain reflects changes in the market valuation of his holdings over the research period, using Greenpeace’s methodology.

By contrast, the €1.486 million share disposal recorded by Shell represents a completed transaction.

Even that figure is gross proceeds, not necessarily Sawan’s net personal profit after acquisition costs, taxes or other relevant considerations.

The two figures should not simply be added together and described as a £6 million personal profit.

That would risk counting different financial concepts as though they were equivalent.

The distinction is particularly important when reporting on executive remuneration.

Clear evidence is more persuasive than exaggerated arithmetic.

Greenpeace demands additional fossil-fuel taxation

Greenpeace argues that the findings reinforce the case for additional taxation of fossil-fuel companies.

The organisation points to the financial pressures experienced by households and businesses when international oil and gas prices rise.

Its campaign position is that additional revenues from the fossil-fuel sector should help finance clean-energy investment and measures addressing climate-related damage.

Critics of additional windfall taxation, however, argue that poorly designed taxes can discourage investment, reduce future energy production and create uncertainty for projects involving significant long-term capital expenditure.

Those competing arguments are matters of public policy.

The Greenpeace research does not, by itself, establish which tax arrangements would achieve the best economic or environmental outcome.

It does provide evidence relevant to the wider debate about who benefits financially during periods of disruption to energy markets.

What should Shell shareholders ask?

The more immediate question for Shell shareholders concerns executive incentives and corporate governance.

Large listed companies commonly use shares and performance-based awards to align management interests with those of shareholders.

The principle is understandable.

If shareholders benefit from stronger performance, senior executives may also receive higher rewards.

But the design of such arrangements can produce complicated outcomes when share prices rise for reasons that management did not directly create.

An oil executive may benefit from higher commodity prices caused by geopolitical disruption even if the underlying improvement in shareholder returns does not result primarily from superior managerial decisions.

Equally, management may deserve recognition for protecting operations, maintaining cash generation and responding effectively to difficult market conditions.

The challenge for remuneration committees is to distinguish these influences.

For Shell, several questions arise.

First, how does the Remuneration Committee assess the contribution of management performance relative to movements in global oil and gas prices?

Second, how are exceptional geopolitical events considered when evaluating long-term incentive outcomes?

Third, what proportion of executive share awards is linked to operational, financial and energy-transition objectives?

Fourth, how does Shell ensure that incentives encourage decisions in the company’s long-term interests rather than simply rewarding short-term increases in market valuation?

Finally, what information is available to shareholders about the circumstances and applicable controls surrounding major executive share disposals?

These are questions of transparency and accountability, not allegations of misconduct.

Our archive reported Sawan’s share sale months ago

There is an important historical dimension to this story.

On 11 September 2026, royaldutchshellplc.com published:

Shell’s Upstream Boss Cashes In as the Oil-and-Gas Strategy Pays Off

That article examined share transactions involving Shell’s senior management and specifically identified Sawan’s 22 May disposal.

It recorded the same 40,000-share transaction and €1,486,804.20 proceeds now highlighted by Greenpeace.

The earlier article also made clear that the disclosure did not suggest improper conduct.

This is a useful example of the value of maintaining a searchable historical archive.

Today’s Greenpeace investigation introduces a broader calculation of executive shareholding gains during the Iran conflict.

But the underlying Shell share sale was already part of the public regulatory record and had already been examined by this website.

The distinction between an established historical fact and a new interpretation of that fact is important.

It helps prevent the public record from being distorted by the excitement surrounding a newly published campaign or news report.

The Shell Leaks Files perspective

The Independent Shell Archive and The Shell Leaks Files have repeatedly examined the relationship between corporate decision-making, financial rewards, public representations and shareholder accountability.

Historical internal communications and contemporaneous records demonstrate the importance of preserving original evidence.

That principle applies equally to modern regulatory disclosures.

Executive share transactions, remuneration awards, financial results and shareholder distributions form part of the permanent documentary record of how Shell is governed.

The objective is not to assume wrongdoing whenever a senior executive receives a substantial financial benefit.

It is to establish what happened, examine what the company disclosed and assess whether the available evidence supports the claims made about it.

The present case illustrates why that approach matters.

Greenpeace has published a campaigning interpretation of the financial benefits experienced by oil executives during a period of geopolitical instability.

Shell’s regulatory announcements provide independent evidence of Sawan’s share disposal and conditional performance-share award.

Shell’s quarterly results provide the financial context.

Together, those sources support a substantial story about executive remuneration and corporate accountability.

They do not establish improper trading.

A question of reward, responsibility and disclosure

The latest disclosures present a striking picture.

Shell has reported more than $10.8 billion in quarterly adjusted earnings.

Its chief executive has experienced an estimated £4.7 million increase in the value of his shareholding during the Iran conflict, according to Greenpeace.

The company’s own records establish that he sold shares worth almost €1.5 million in May.

And Shell has authorised another $5 billion in share repurchases.

None of these events is inherently improper.

They do, however, illustrate the scale of the financial interests involved when a major energy company operates in markets profoundly influenced by international conflict.

For shareholders, the central issue is whether executive incentives appropriately reward management performance and sustainable long-term value creation.

For the wider public, it is reasonable to ask how the benefits and costs of energy-market disruption are distributed.

The evidence does not justify accusing Shell’s chief executive of wrongdoing. It does justify asking whether executive reward arrangements sufficiently distinguish management achievement from the financial effects of global crises.

That is the question worth putting to Shell.

And it is one the company’s own regulatory disclosures help bring into focus.

Principal sources

1. Greenpeace UK — 30 October 2026

North Sea Oil Bosses Enjoy £19 Million Personal Windfall Since Outbreak of Iran War

Original Greenpeace investigation providing the estimated £19 million combined shareholding appreciation and the £4.7 million estimate relating to Wael Sawan.

Greenpeace — Oil Majors Share Gains Methodology, 28 October 2026

Supporting methodology supplied by Greenpeace. Its calculations and assumptions should be treated as the organisation’s estimates.

2. Shell plc — Official regulatory disclosure, 22 May 2026

Director/PDMR Shareholding — Wael Sawan

Primary corporate evidence confirming the sale of 40,000 ordinary shares for €1,486,804.20.

Shell plc — Form 6-K, 22 May 2026

The shareholding notification furnished to the US Securities and Exchange Commission.

3. Shell plc — Official regulatory disclosure, 21 May 2026

Director/PDMR Shareholding — Conditional Performance Share Awards

Primary evidence recording the conditional award of 82,987 performance shares to Wael Sawan.

4. Shell plc — 29 October 2026

Third Quarter 2026 and Nine Months Unaudited Results

Primary source for Shell’s quarterly adjusted earnings, cash flow, shareholder distributions and business performance.

5. Previous Independent Shell Archive reporting

Shell’s Upstream Boss Cashes In as the Oil-and-Gas Strategy Pays Off — 11 September 2026

Previous coverage confirming that Sawan’s May share disposal was already documented by this website.

Shell’s $10.8 Billion Profit Bonanza: A $2.1 Billion Biogas Write-Down as LNG Canada Gains $1.8 Billion in Value — 29 October 2026

Our detailed examination of Shell’s latest quarterly financial disclosures.

Editorial note: This article distinguishes Greenpeace’s estimates and campaigning claims from the financial transactions and other information confirmed in Shell’s official disclosures. An increase in the market value of a shareholding is not equivalent to a realised cash gain. A share disposal is not evidence of insider dealing or other misconduct. No such allegation is made against Wael Sawan. Shell plc is invited to provide any factual correction or explanation it wishes to place on the record.

Shell CEO’s Shares Gain £4.7 Million During Iran War — Regulatory Filing Confirms €1.49 Million Share Sale as Oil Giant Reports $10.8 Billion Profits was first posted on October 30, 2026 at 8:22 pm.
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Shell’s latest financial statements reveal an anticipated $6.4 billion non-cash accounting loss arising from the transformation of its Dutch pension arrangements. The disclosure raises important questions about pension governance, regulatory oversight and the financial consequences of the transition — but it does not establish that pensioners will suffer corresponding losses.

By John Donovan — 30 October 2026

Just one day after Shell plc announced spectacular third-quarter earnings and another $5 billion share-buyback programme, a striking disclosure in the company’s financial statements deserves closer attention.

On page 33 of its report for the quarter ended 30 September 2026, Shell reveals that it expects to recognise an estimated $6.4 billion non-cash accounting loss in the fourth quarter of this year.

The anticipated charge arises from the restructuring of the Dutch pension arrangements operated by Stichting Shell Pensioen Fonds (SSPF).

The amount is extraordinary.

It is larger than Shell’s newly announced $5 billion share-buyback programme and comes at a time when the company is reporting exceptionally strong profits.

Yet this is not a straightforward case of Shell losing $6.4 billion in cash.

Nor does the disclosure establish that employees or pensioners face a corresponding reduction in their retirement benefits.

The explanation lies in a complicated intersection of Dutch pension reform, international accounting standards and the treatment of defined-benefit pension obligations.

Understanding what Shell has actually disclosed — and what remains unanswered — is essential.

The $6.4 billion disclosure

Shell’s financial statements describe the pending transition of its Dutch defined-benefit pension fund to a defined-contribution arrangement.

The company states that the transition is expected to take effect on 1 January 2027.

The associated accounting settlement is expected to occur on 31 December 2026.

At that point, according to Shell, the existing defined-benefit plan will cease to be recognised in the company’s accounts in its present form.

Under the relevant accounting treatment, Shell expects this derecognition to produce a substantial charge in its consolidated income statement.

The estimated amount, calculated at 30 September 2026, is $6.4 billion.

Shell explicitly describes the anticipated charge as non-cash.

It also warns that the figure remains subject to actuarial remeasurement during the fourth quarter and may therefore change.

This distinction matters.

A charge recorded in a corporate income statement does not necessarily represent a cash payment, an investment loss of the same amount or a reduction in the pensions payable to individual members.

Nevertheless, an accounting adjustment of this magnitude is financially material and deserves scrutiny.

Why is Shell changing its Dutch pension arrangements?

The background is a fundamental reform of the Netherlands’ pension system.

On 1 July 2023, the Dutch Wet toekomst pensioenen (Future Pensions Act) came into effect.

The legislation introduced a substantial restructuring of occupational pension arrangements, with existing schemes required to complete their transitions before 1 January 2028.

The reform changes how pension rights, investment risks and retirement outcomes are organised and communicated.

Shell’s Dutch pension fund has been preparing to comply with the new framework.

According to Shell’s financial statements, the SSPF trustee board formally accepted the transition plan in July 2025.

The planned effective date is 1 January 2027.

Importantly, Shell is not presenting this restructuring as an entirely voluntary decision to abandon its existing arrangements.

It forms part of a wider legislatively mandated transformation of the Dutch pension system.

Nevertheless, the financial and governance consequences for Shell remain significant.

Dutch regulator gives conditional clearance

Shell’s disclosure identifies an important regulatory development.

On 2 September 2026, De Nederlandsche Bank (DNB), the Dutch central bank and pension supervisor, issued its decision not to prohibit the transfer of accrued pension entitlements into the new pension arrangement.

The Dutch terminology is Besluit geen verbod op invaren.

The decision was conditional.

Shell states that the funding ratio at the point of transition must remain within an agreed range.

Moreover, final approval by the SSPF trustee board was still outstanding when the quarterly results were published.

Shell expects that decision during the fourth quarter of 2026.

Consequently, the proposed transition has not yet been presented by Shell as an unconditional, completed event.

The precise outcome remains dependent on the relevant conditions and approvals.

That distinction should not be overlooked.

What does a $6.4 billion non-cash loss actually mean?

This is perhaps the most important question.

Under International Accounting Standard IAS 19, Employee Benefits, companies must account for defined-benefit pension commitments according to prescribed rules governing pension obligations, pension assets, actuarial assumptions and the recognition of surpluses or deficits.

In a conventional defined-benefit arrangement, the sponsoring employer may remain exposed to certain risks associated with meeting promised pension benefits.

A defined-contribution arrangement generally involves a different allocation of risks and responsibilities.

However, the precise legal and economic consequences depend on the structure of the scheme.

Shell’s proposed transition involves the derecognition of its existing defined-benefit arrangement.

The company explains that the accounting consequences include the operation of the asset ceiling provisions of IAS 19.

These provisions can restrict how much of a pension fund surplus an employer is permitted to recognise as an asset in its financial statements.

Shell states that in the third quarter of 2025 it recognised an adjustment reducing the pension fund surplus recognised in its accounts to nil, together with a liability associated with minimum funding requirements.

That adjustment produced a loss in other comprehensive income.

The asset ceiling has continued to be monitored and remeasured.

With the expected transition at the end of 2026, a further accounting consequence is anticipated.

The resulting $6.4 billion charge is expected to pass through Shell’s fourth-quarter income statement.

But there is an essential distinction between an accounting loss and money physically leaving the company.

Shell’s disclosure does not establish that it must pay $6.4 billion into the pension fund, that the fund has lost $6.4 billion in assets, or that members’ pensions will be reduced by that amount.

Indeed, the company’s explanation suggests that the anticipated charge is principally associated with accounting recognition and derecognition as the scheme changes.

The correct interpretation requires examination of the detailed actuarial and accounting calculations.

Those calculations are not fully reproduced in the quarterly disclosure.

What about Shell’s existing pension position?

Shell provides additional context in the same financial report.

At 30 September 2026, its consolidated balance sheet recorded:

Retirement benefits 30 September 2026 31 December 2025 Non-current pension-related assets $5.737 billion $5.052 billion Non-current pension-related liabilities $6.262 billion $7.136 billion Net recognised deficit $525 million $2.084 billion

These figures concern Shell’s recognised retirement-benefit assets and liabilities across its relevant plans, rather than representing the funding position of SSPF alone.

Shell attributes the improvement in the net position principally to higher discount rates reducing the measured retirement-benefit obligations, partly offset by investment returns below expectations.

That improvement provides an important contrast with the impending $6.4 billion accounting charge.

It illustrates why the value of pension assets, the actuarial measurement of pension commitments and the accounting consequences of restructuring must be considered separately.

A large pension-related charge in the income statement does not necessarily mean that the underlying pension scheme has experienced an equivalent economic deterioration.

What will happen to Shell pensioners?

The central concern for many current and former employees will be understandable:

Will the transition affect the pensions they receive?

Shell’s quarterly financial disclosure does not provide enough information to determine how every category of member will be affected.

The transition involves accrued pension entitlements, but its implications for individuals depend on the final scheme rules, funding position, allocation mechanisms and relevant Dutch legal safeguards.

It would therefore be irresponsible to suggest that Shell’s pensioners are about to lose $6.4 billion in promised retirement benefits.

The company’s announcement makes no such claim.

Equally, it would be premature to conclude that every pension beneficiary will experience precisely the same economic outcome under the new arrangements.

Those questions require examination of the SSPF transition plan and the communications issued to members.

Independent pension specialists may also be able to explain the consequences more fully.

Why should Shell shareholders be interested?

There are several reasons.

First, the anticipated charge is substantial in absolute terms.

A $6.4 billion loss recorded in a quarterly income statement can materially affect reported statutory earnings.

Second, Shell’s management will need to explain the accounting consequences clearly so that investors do not confuse a non-cash pension adjustment with a deterioration in the company’s operating performance.

Third, the transition represents a major governance development involving pension trustees, a national regulator and the sponsor of a significant retirement arrangement.

Fourth, there are legitimate questions about the longer-term consequences of changing the nature of Shell’s pension obligations and associated financial risks.

Finally, the disclosure warrants attention because the accounting treatment is not intuitive.

Shareholders reading headlines about billion-dollar profits, share buybacks and pension losses may reasonably struggle to reconcile the figures.

Shell has an interest in ensuring that its explanations are sufficiently clear to prevent misunderstanding.

The contrast with Shell’s quarterly profits

The timing is noteworthy.

On 29 October 2026, Shell announced adjusted third-quarter earnings of $10.814 billion.

The same results included a $2.116 billion impairment relating to a European biogas asset and a $1.787 billion reversal of an earlier impairment associated with a North American Integrated Gas asset.

Our previous investigation examined the contrast between those two energy investments.

The pension disclosure introduces a different but equally significant issue.

Whereas the biogas impairment reflects revised expectations about the recoverable value of a commercial asset, the projected pension charge arises from a change in the accounting treatment of retirement arrangements.

These are fundamentally different financial events.

Nevertheless, all three demonstrate why investors should look beyond headline adjusted earnings and examine the accompanying financial statement notes.

Some of the most consequential information in corporate reporting appears not in the headline announcements, but in the explanations accompanying the accounts.

The Shell historical archive perspective

The Independent Shell Archive has long examined questions surrounding the company’s corporate governance, financial reporting, legal responsibilities and relationships with employees.

The pension disclosure is relevant to that historical record.

Shell’s relationship with its workforce has developed over more than a century, encompassing changing employment practices, restructuring, pension commitments and corporate governance arrangements.

The transition now under way in the Netherlands represents another significant chapter in that history.

There is no basis in the present disclosure for suggesting misconduct by Shell, its pension trustees or the Dutch regulator.

Nor is there evidence that the anticipated accounting charge conceals an undisclosed cash liability of the same amount.

What the disclosure does establish is that Shell expects a major financial reporting consequence from a fundamental change in its Dutch retirement arrangements.

For an independent archive concerned with preserving contemporaneous corporate evidence, that is sufficient reason to document the event carefully.

It will also be important to preserve the distinction between what Shell disclosed before the transition and what ultimately occurs when the final arrangements take effect.

That is the same documentary principle underpinning The Shell Leaks Files: preserve the original evidence, identify what was known at the time, and compare statements with subsequent developments.

Questions Shell should answer

In the interests of transparency, Shell could usefully provide fuller explanations addressing several questions.

1. How is the $6.4 billion calculated?

What are the principal accounting components of the expected loss, and how much arises from the reversal of previously recognised pension-related balances?

2. What is the expected cash impact?

Although Shell describes the charge as non-cash, are there separate contributions, payments or funding obligations associated with the transition?

3. What happens to pension obligations?

How will the transition alter Shell’s future exposure to pension funding requirements and actuarial risks?

4. What protections exist for pension members?

How will accrued entitlements and the interests of current employees, deferred members and existing pensioners be treated?

5. What remains subject to approval?

Which decisions must still be taken by the SSPF trustee board, and what would happen if the agreed funding conditions were not satisfied?

6. How will the charge affect reported earnings?

Will Shell classify the anticipated $6.4 billion expense as an identified item excluded from adjusted earnings, and what additional reconciliation information will be provided?

These are questions of financial reporting, governance and pension administration.

They are not allegations of wrongdoing.

A significant disclosure deserving a clear explanation

Shell’s financial statements provide an unusually stark figure: a projected $6.4 billion non-cash loss arising from a change in pension arrangements.

The company’s explanation identifies the accounting mechanism and the regulatory background.

But it leaves important questions about the detailed calculation and practical implications for the pension arrangements.

The transition has not yet been completed.

Final trustee approval remains outstanding, and the estimated loss may change before the expected settlement date.

For employees, pensioners and shareholders alike, the priority should be clarity rather than alarm.

The public record establishes that a substantial accounting adjustment is anticipated. It does not establish that pension beneficiaries face a corresponding loss.

The proper question is not simply why Shell expects to recognise a $6.4 billion loss, but how that figure arises, what financial responsibilities change, and whether the transition protects the interests of the people whose retirement arrangements are being transformed.

Those questions deserve answers before the new pension arrangements take effect.

And the Independent Shell Archive will preserve the disclosures so that the company’s explanations can be evaluated against the eventual outcome.

Principal sources

Shell plc — Third Quarter 2026 and Nine Months Unaudited Results, 29 October 2026

Official Shell financial statements and quarterly results

See Note 7, particularly page 33, under the headings Retirement benefits and Dutch pension reform. This is the principal source for the $6.4 billion estimate, regulatory decision, transition timetable and accounting explanation.

Shell SEC filings

Shell’s official investor portal providing access to its regulatory and SEC disclosures.

Related Independent Shell Archive reporting

Shell’s $10.8 Billion Profit Bonanza: A $2.1 Billion Biogas Write-Down as LNG Canada Gains $1.8 Billion in Value — 29 October 2026

Our analysis of other material accounting developments disclosed in the same quarterly financial report.

Editorial note: This article is based primarily on Shell plc’s unaudited financial statements published on 29 October 2026 and supplied as part of its US regulatory reporting. The anticipated $6.4 billion pension-related charge is Shell’s estimate, not a completed loss. The estimate remains conditional and subject to change. The article does not allege that pension-fund assets or individual pension benefits have fallen by that amount, or that Shell or its pension trustees have acted improperly. Commentary and questions are independent editorial analysis.

Shell plc and Stichting Shell Pensioen Fonds are invited to provide factual corrections, accounting clarifications or information about the transition’s implications for pension members. Any substantive response will be considered for publication.

The next documentary checkpoint is the SSPF trustee board’s final decision and Shell’s fourth-quarter financial statements, when the company should be able to confirm the actual accounting treatment and amount.

Shell’s $6.4 Billion Pension Bombshell: SEC Disclosure Reveals Major Accounting Loss Expected as Dutch Retirement Scheme Changes was first posted on October 30, 2026 at 2:22 pm.
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SLF-2007-102 The Sakhalin Papers XCII: The Russian Exit — Shell’s 28 February 2022 Announcement and the Financial Reckoning Four days after Russia launched its full-scale invasion of Ukraine, Shell announced that it would withdraw from its major Russian joint ventures and end its involvement in Nord Stream 2. The decision brought an extraordinary chapter in the company’s history towards its conclusion. The financial consequences were immediate: a $1.614 billion impairment relating to Sakhalin II, a $1.126 billion write-down of its Nord Stream 2 loan and billions more in Russia-related charges. Yet Shell’s subsequent accounts reveal that the withdrawal was neither instantaneous nor complete. The original corporate announcements, SEC filings and contemporaneous reporting establish precisely what happened — and why the consequences remained unresolved years later.

Archive reference: SLF-2007-102
Publication date: 29 October 2026
Collection: The Sakhalin Papers — Shell, Gazprom and Russia
Previous instalment: SLF-2007-101, The Sakhalin Papers XCI, 28 October 2026

Principal authenticated records: Shell plc announcement of 28 February 2022; Shell’s Nord Stream 2 financing announcement of 24 April 2017; Shell’s operational update of 7 April 2022; first-quarter financial results of 5 May 2022; Shell Annual Report and Form 20-F 2022; Shell Annual Report and Form 20-F 2025, filed with the US Securities and Exchange Commission on 12 March 2026.

Contemporaneous reporting: Reuters, February–April 2022; Interfax, 5 May 2022; contemporary financial reporting on Shell’s Russian withdrawal and subsequent impairment charges.

Related legal record: The Russian restructuring of Sakhalin II under Presidential Decree No. 416 of 30 June 2022; subsequent Moscow proceedings identified as Case No. A40-241354/2024.

Evidence classification: Authenticated Shell corporate announcements, contemporaneous financial disclosures, SEC filings, independent reporting, official Russian measures and separately identified editorial commentary. Corporate intentions are distinguished from completed transactions. Financial impairments are distinguished from cash payments. Pending legal allegations are not presented as judicial findings.

Introduction: Four days that ended decades of commercial ambition

On 24 February 2022, Russian armed forces launched their full-scale invasion of Ukraine.

Four days later, Shell made an announcement that would have been almost unimaginable during the earlier years of its partnership with Gazprom.

The company declared that it intended to withdraw from its Russian joint ventures.

Its decision encompassed Sakhalin II, Salym Petroleum Development and the Gydan exploration venture.

Shell also announced that it intended to end its involvement in Nord Stream 2.

The implications extended beyond the abandonment of individual investments.

Shell had spent decades developing commercial relationships with Russia.

Sakhalin II had been one of its most ambitious international projects.

Nord Stream 2 represented another major commitment to the future of Russian natural gas supplies.

Now both were being brought to an end from Shell’s perspective.

But there is a documentary distinction that matters.

On 28 February 2022, Shell announced an intention to withdraw. It did not announce that every Russian investment had already been sold, every contract terminated or every financial obligation extinguished.

That distinction becomes central to understanding the financial and legal consequences that followed.

The original announcement survives in Shell’s corporate records.

It was also reproduced contemporaneously by RoyalDutchShellPlc.com.

The documents allow us to reconstruct the company’s position without relying upon retrospective interpretations.

Primary sources: Shell’s original announcement, 28 February 2022 and RoyalDutchShellPlc.com’s contemporary publication.

1. The original announcement: Shell makes its decision

The announcement was issued by Shell plc on 28 February 2022.

It identified the company’s principal Russian interests and confirmed that the Board intended to withdraw from its partnerships involving Gazprom and related entities.

The company’s chief executive, Ben van Beurden, condemned the Russian invasion.

He described the military aggression as senseless and said that Shell was shocked by the resulting loss of life in Ukraine.

Van Beurden declared:

“Our decision to exit is one we take with conviction.”

He also emphasised Shell’s immediate concern for the safety of its personnel in Ukraine and Russia.

The announcement recognised the importance of maintaining secure energy supplies to European and other markets.

It acknowledged that Shell would need to work through the commercial implications in discussions with governments and in accordance with applicable sanctions.

These qualifications were significant.

Shell was making a political and commercial decision in response to an extraordinary international crisis.

But the company was also acknowledging that implementation would involve complex questions concerning energy supplies, investment rights and contractual obligations.

The distinction between making the decision and completing the withdrawal was present from the beginning.

That is apparent from the language of Shell’s own announcement. GlobeNewswire

2. What Shell was actually leaving

The four principal investments identified in the announcement were not legally or financially identical.

Understanding their different structures is essential to understanding the subsequent losses.

Sakhalin II

Shell held a 27.5% interest in the Sakhalin II oil and liquefied natural gas development.

The other shareholders were Gazprom, Mitsui and Mitsubishi.

Gazprom held the controlling interest, acquired through the transaction negotiated in December 2006 and completed in April 2007.

Shell remained a substantial minority shareholder and continued to contribute technical expertise.

The investment was therefore an equity participation in an operating energy development.

Salym Petroleum Development

Shell held a 50% interest in Salym Petroleum Development, operating with Gazprom Neft in western Siberia.

This was a producing oil venture rather than an LNG export development.

It had its own assets, operating arrangements and accounting treatment.

Gydan

Shell held a 50% interest in the Gydan exploration venture with Gazprom Neft.

Unlike Sakhalin II and Salym, Gydan was still at the exploration stage.

Shell’s February announcement expressly stated that the venture had no production.

Nord Stream 2

This was fundamentally different.

Shell was not an equity shareholder in Nord Stream 2 AG under the financing arrangements established in April 2017.

Gazprom remained the sole shareholder.

Shell was one of five European energy companies that had agreed to provide financing and guarantees.

Its maximum commitment was approximately €950 million.

The five participants were Shell, ENGIE, OMV, Uniper and Wintershall.

Their combined commitments covered up to half of the project’s estimated €9.5 billion cost.

The distinction is crucial.

Shell’s Sakhalin II exposure was an equity investment. Its Nord Stream 2 exposure was principally a financing arrangement.

The subsequent impairments therefore reflected different financial assets and different accounting considerations.

Sources: Shell’s February 2022 investment summary and Contemporaneous account of the April 2017 Nord Stream 2 financing agreement. Ocean News & Technology

3. The financial position before the exit

Shell’s 28 February announcement contained two figures that deserve particular attention.

At the end of 2021, the company reported approximately:

$3 billion in non-current assets associated with the Russian ventures identified in its announcement.

Shell also disclosed that its share of adjusted earnings from the Sakhalin Energy and Salym joint ventures during 2021 amounted to approximately:

$700 million.

Those figures demonstrate that the Russian investments were not merely historical interests awaiting disposal.

They were still contributing to Shell’s financial performance.

Sakhalin II was an established LNG producer.

Salym was producing oil.

Nord Stream 2 was intended to become an important additional route for Russian gas exports to Europe.

But the figures should not be confused.

The $3 billion represented a reported balance-sheet amount for non-current assets in the relevant Russian ventures.

The $700 million represented adjusted earnings attributable to Shell from two operating ventures during 2021.

Neither figure constituted the total market value of all Shell’s Russian commercial relationships.

Nor did either establish the amount that Shell would eventually lose.

The company’s subsequent financial charges included exposures extending beyond those non-current investments.

That helps explain why the eventual withdrawal-related charges exceeded the approximately $3 billion figure highlighted in February. GlobeNewswire

4. The historical question: How did Shell reach this point?

It would be misleading to portray Shell’s Russian exposure as a sudden development.

The relationship had accumulated over decades.

In December 2006, Shell and its Japanese partners agreed that Gazprom would acquire control of Sakhalin Energy.

The agreement followed months of environmental controversy, regulatory pressure and negotiations concerning the project’s costs and ownership.

Shell retained a substantial minority stake.

The transaction was worth approximately $7.45 billion.

The earlier instalments of The Sakhalin Papers have examined the circumstances surrounding that agreement in considerable detail.

They have also examined the internal Shell correspondence disclosed during the Sakhalin controversy and the subsequent involvement of Russian environmental regulator Oleg Mitvol.

Those documents establish a complicated history.

They do not establish that the 2006 transaction was legally invalid.

Nor do they prove that the leaked correspondence caused Gazprom to obtain control.

But they demonstrate that Shell’s relationship with Russian state-controlled energy interests had already encountered serious political and regulatory difficulties.

The Nord Stream 2 relationship developed against another background of controversy.

Poland objected to the project’s proposed ownership arrangements.

The original structure was replaced by financing agreements.

European legislation subsequently changed.

American sanctions disrupted construction.

Ukraine repeatedly expressed concern about the strategic consequences of additional Russian gas transportation routes bypassing its territory.

Germany’s certification process became increasingly complicated.

By February 2022, Shell had invested financially in a completed pipeline that was still unable to begin commercial operations.

These developments were documented before Russia’s full-scale invasion.

The invasion dramatically transformed the circumstances, but it did not create every underlying political and commercial risk from nothing.

The relevant distinction is between risks that were identifiable beforehand and the precise consequences that could reasonably have been predicted.

The surviving public documents do not establish Shell’s complete internal assessment of those risks.

They do establish that the controversies were already visible.

See The Sakhalin Papers XCI — 28 October 2026 and The Sakhalin Papers LXXVI — The Nord Stream 2 Financing Arrangement.

5. April 2022: The first financial warning

On 7 April 2022, Shell issued a trading and operational update ahead of its first-quarter results.

The announcement included a warning about the financial consequences of withdrawing from Russia.

Shell estimated that impairments and additional charges relating to its Russian activities could amount to:

$4 billion to $5 billion

The estimate was expressed on a post-tax basis.

It included possible impairments of non-current assets and additional charges arising from matters such as receivables, credit losses and onerous contracts.

This was a broader assessment than the approximately $3 billion balance-sheet figure disclosed in February.

The announcement also explained an important accounting distinction.

The anticipated charges would be treated as identified items and excluded from the company’s adjusted earnings measure.

That meant that Shell could report strong adjusted earnings while simultaneously recognising substantial Russia-related losses in its statutory financial statements.

The market circumstances made that possibility especially significant.

Oil and gas prices had risen sharply.

Shell’s trading businesses were operating in unusually volatile conditions.

The financial impact of abandoning Russian investments was therefore occurring alongside favourable developments elsewhere in the company’s global portfolio.

This was not necessarily contradictory.

It reflected the structure of a large international energy business, with different activities exposed to different financial consequences.

Authenticated source: Shell — First Quarter 2022 Update Note, 7 April 2022.

6. May 2022: The audited accounting trail begins to emerge

On 5 May 2022, Shell published its unaudited first-quarter results.

The figures provided the first detailed accounting breakdown of the Russian withdrawal.

Shell reported pre-tax charges of:

$4.235 billion

The corresponding post-tax charge was:

$3.894 billion

The results identified the principal components.

The Sakhalin II impairment amounted to $1.614 billion.

The Nord Stream 2 loan write-down amounted to $1.126 billion.

Further impairments and charges related to Salym, Gydan, Russian marketing operations, trading contracts and other assets.

The significance of the document is not simply the size of the loss.

It demonstrates that Shell was dealing with several different forms of exposure simultaneously.

Some involved investments in producing assets.

Some involved a loan.

Others involved leases, receivables, marketing operations and contractual commitments.

The company had not simply written a cheque for $3.894 billion.

Much of the charge reflected reductions in the accounting values of assets and other recognition of losses.

Impairment charges are not necessarily equivalent to immediate cash expenditure.

This matters when assessing the economic cost of the decision. Shell Plc

7. Sakhalin II: The $1.614 billion impairment

The Sakhalin II charge deserves separate examination because it concerns the investment at the centre of this documentary series.

Shell’s first-quarter accounts recorded an impairment of:

$1.614 billion

The company explained how it had assessed the recoverable value of its interest.

The calculation was based upon risk-adjusted dividends declared in relation to Sakhalin Energy’s 2021 results.

The first part of those dividends was received in April 2022.

This is a revealing accounting detail.

Shell was no longer valuing its Sakhalin investment as though it would continue to participate normally in the project’s future profits.

Instead, the recoverable amount was being assessed in the context of withdrawal and the cash distributions that might still be obtained.

Another significant development followed.

From 1 April 2022, Shell considered that it had lost significant influence over Sakhalin Energy.

The company identified the resignation of its executive directors and the withdrawal of managerial and technical personnel as the reasons.

That resulted in a change in accounting classification.

The investment was no longer treated as an associate under the equity method.

It became a financial asset measured at fair value.

Shell specified that the reclassification itself had no immediate financial impact.

The distinction is important.

The impairment, the loss of significant influence and the later restructuring of the project were separate accounting and corporate events.

They should not be collapsed into a single supposed sale. SEC

8. Nord Stream 2: The $1.126 billion loan disappears from the balance sheet

The second major charge concerned Nord Stream 2.

Shell’s accounts recorded a complete write-down of its outstanding loan:

$1.126 billion

This figure should be understood in the context of Shell’s original financing agreement.

On 24 April 2017, the company committed to provide financing and guarantees of up to approximately €950 million.

The arrangement did not make Shell a shareholder in Nord Stream 2 AG.

It made Shell a financier.

The original agreement distinguished between an initial long-term funding facility and further financing or guarantees available according to the project’s requirements.

Shell’s 2022 annual report subsequently confirmed that its final loan instalments had been made during the second quarter of 2020.

That date matters.

By then, the project had already encountered substantial regulatory and political difficulties.

American sanctions had disrupted construction.

European gas legislation had changed.

Legal proceedings concerning the pipeline’s regulatory treatment were continuing.

Shell nevertheless completed its financing contributions under the arrangements then applicable.

Following the events of February 2022, the company reassessed the recoverability of the loan.

It concluded that the full outstanding amount should be written down.

A write-down does not necessarily mean that the underlying legal debt has been extinguished.

It means that the company has recognised the relevant reduction in the asset’s accounting value.

The documentary record therefore establishes a financial loss recognised by Shell.

It does not, by itself, establish that every potential contractual recovery right was legally cancelled.

Authenticated sources: Shell’s 2022 first-quarter results and the SEC-hosted 2022 annual-report note on withdrawal from Russia.

9. The other Russian ventures: More than Sakhalin and Nord Stream 2

The first-quarter accounts also recorded impairments relating to Shell’s other Russian operations.

Salym Petroleum Development incurred an impairment of approximately $233 million.

Gydan incurred an impairment of approximately $153 million, together with additional charges.

Shell’s Russian marketing business incurred substantial charges relating to non-current assets and other obligations.

These included the company’s service-station network and lubricants activities.

Other charges concerned contractual exposures and rights-of-use assets.

Together, these items help explain why Shell’s withdrawal-related charges extended beyond its two most prominent Russian investments.

They also demonstrate that the February announcement affected a range of operating activities.

Sakhalin II was a mature LNG development.

Salym was an operating oil business.

Gydan was an exploration venture.

Nord Stream 2 was a pipeline-financing exposure.

Shell’s retail and lubricants operations were another category entirely.

Different exit mechanisms were therefore required.

Some operations could be sold.

Others required withdrawal from management.

Some contractual relationships had to be wound down.

Still others became entangled in Russian legislation introduced after the invasion.

The financial statement does not support treating all these exposures as interchangeable. Shell Plc

10. The final 2022 figure: $4.170 billion before tax

There is an important difference between Shell’s first-quarter charges and its final reported position for 2022.

The first-quarter results recorded:

$4.235 billion before tax and $3.894 billion after tax.

The full-year accounts subsequently recorded net charges of:

$4.170 billion before tax

The corresponding full-year post-tax amount was:

$3.804 billion

These are the figures reported in Shell’s 2022 annual accounts.

The difference reflects subsequent accounting movements during the year.

The first-quarter and full-year charges should not be added together.

The annual figure represents the net withdrawal-related charges recognised for 2022.

It incorporates the effects recorded during the year, including later adjustments.

The full-year note allocates the charges across several income-statement categories.

It records $1.614 billion under the share of profits and losses of joint ventures and associates.

It records $1.116 billion under interest and other income or expenses.

It also records charges in revenue, depreciation and amortisation, administrative expenses and other categories.

The full-year amount in the interest category should not be confused with the original $1.126 billion Nord Stream 2 loan write-down.

The latter is the amount specifically identified in Shell’s first-quarter disclosure.

The full-year income-statement line reflects the net balance of relevant items recorded in that category.

This distinction is essential for an accurate financial chronology.

The authenticated full-year figures establish the scale of Shell’s recognised Russia-related losses.

They do not establish that the entire amount was attributable to Sakhalin II, Nord Stream 2 or any single Russian operation.

Primary accounting source: US Securities and Exchange Commission — Shell’s 2022 Russia Withdrawal Disclosures.

11. The apparent paradox: Billions written off while profits surged

Shell’s first-quarter 2022 results contained another striking figure.

Adjusted earnings reached:

$9.130 billion

This was a substantial increase from the previous quarter.

The company attributed the improvement primarily to higher realised energy prices, stronger trading contributions and other favourable financial developments.

The same results included the approximately $3.9 billion post-tax charge associated with withdrawing from Russia.

At first sight, the two figures appear difficult to reconcile.

But they measure different aspects of financial performance.

Adjusted earnings exclude certain identified items.

The Russian withdrawal charges were classified among those items.

Shell’s statutory income attributable to shareholders was approximately $7.116 billion for the quarter.

It would therefore be misleading to suggest that the Russia-related losses eliminated Shell’s profitability.

It would be equally misleading to suggest that strong adjusted earnings meant the Russian losses were insignificant.

Both figures were relevant.

The company was recognising substantial losses from particular investments while generating considerable profits from its remaining global operations.

The same quarter’s results showed operating cash flow of approximately $14.8 billion.

Shell also continued its shareholder-distribution programme.

In its February announcement, the company had reiterated an $8.5 billion share buyback programme for the first half of 2022.

The financial consequences of withdrawal were therefore significant but did not prevent Shell from maintaining substantial shareholder distributions.

That is an important distinction for investors examining the company’s capital allocation and risk management. Shell Plc

12. The exit was not instantaneous

Shell’s subsequent annual report provides a clearer picture of how the withdrawal unfolded.

On 1 April 2022, Shell recorded the loss of significant influence over Sakhalin Energy.

On 30 June, Russia issued Presidential Decree No. 416.

The decree required the transfer of Sakhalin Energy Investment Company Ltd’s project rights and obligations to a newly created Russian company.

Shell’s accounts later stated that the relevant transfers purportedly occurred on 17 August 2022.

On 1 September, Shell formally advised the Russian authorities that it would not apply for shares in the replacement company.

It also objected to the transfers and reserved its rights and remedies.

This was not an ordinary negotiated divestment in which Shell identified a purchaser, agreed a price and completed the transaction on conventional commercial terms.

The original decision to leave was Shell’s.

The subsequent restructuring was imposed through Russian presidential action.

The company’s refusal to participate in the replacement structure was another distinct decision.

Shell’s annual report recorded the carrying value of its Sakhalin II investment as zero at 31 December 2022.

Yet Shell continued to hold shares in the original Bermuda-incorporated Sakhalin Energy Investment Company.

The legal and financial consequences were therefore more complicated than the simple statement that Shell had left Russia.

These events were examined separately in our September 2026 Sakhalin investigations.

Their relevance here is that they demonstrate the practical consequences of the February announcement.

Announcing withdrawal was an event. Completing the disentanglement was a prolonged process. SEC

13. The legal aftermath: Russia’s 2024 claim

The consequences did not end with the 2022 financial statements.

On 2 October 2024, Russia’s Prosecutor General filed proceedings in Moscow against eight Shell-group entities.

The proceedings are identified as:

Case No. A40-241354/2024.

Shell’s subsequent annual reporting describes allegations relating to its withdrawal from Sakhalin Energy Investment Company.

The Russian prosecutor also seeks approximately €1.5 billion from Shell Energy Europe Limited for alleged unpaid gas deliveries during 2022.

A further element concerns approximately 94 billion roubles said to have been reserved for Shell as compensation associated with its former Sakhalin interest.

The prosecutor seeks to have those funds applied against part of the alleged gas debt.

These are separate commercial relationships that became entangled in the Russian proceedings.

One concerns Sakhalin equity.

Another concerns a gas-supply relationship involving Gazprom Export and Shell Energy Europe.

They should not be mistaken for the same transaction.

Most importantly, the Russian allegations are contested.

Shell’s latest annual report available for this review — covering 2025 and filed with the SEC on 12 March 2026 — states that the proceedings remain ongoing.

The company says it cannot reliably estimate the amount or timing of any eventual payment obligation.

The existence of the proceedings does not establish Shell’s liability.

Nor does it establish that Russia’s proposed use of the Sakhalin compensation is legally justified.

The case nevertheless illustrates the extraordinary legal complexity of Shell’s withdrawal.

More than four years after the February 2022 announcement, the company’s historical Russian relationships continued to feature in litigation and financial disclosures.

Authenticated record: Shell’s 2025 Form 20-F, filed 12 March 2026. The Russia litigation disclosure is reproduced in the SEC-hosted filing note.

14. The difficult question of commercial responsibility

The decision to leave Russia followed circumstances of exceptional gravity.

Shell’s position was that Russia’s invasion of Ukraine made continued participation in the identified ventures unacceptable.

Its chief executive publicly condemned the aggression.

The company also had responsibilities to employees, customers and shareholders.

But for a documentary history, the question of why Shell eventually withdrew must be separated from the question of how the company managed its exposure beforehand.

The Sakhalin II investment had survived the political and regulatory confrontation of 2006.

Shell had subsequently continued working with Gazprom.

Nord Stream 2 was financed despite substantial controversy over its geopolitical consequences.

The pipeline’s construction proceeded while European and American objections intensified.

These are established elements of the historical record.

They raise legitimate questions about corporate risk assessment.

How did Shell evaluate the possibility of a major deterioration in relations between Russia and the West?

What weight did it give to warnings concerning Russian state influence over strategic energy infrastructure?

How did it assess the potential consequences of sanctions?

What assumptions supported the recoverability of its Nord Stream 2 financing?

And what contingency arrangements existed for withdrawing from an operating venture such as Sakhalin II?

These are reasonable questions for shareholders.

But the publicly available documents examined for this instalment do not establish the complete deliberations of Shell’s Board.

They do not disclose every internal risk assessment.

They do not establish that the company’s directors anticipated the full-scale invasion.

Nor do they justify an allegation that Shell knowingly accepted certain financial losses in advance.

The evidence supports scrutiny of the decisions.

It does not establish improper motives.

15. An overlooked detail: Shell’s announcement already contained the limits of the withdrawal

The February announcement concerned equity partnerships and Nord Stream 2.

It did not initially constitute an unconditional promise to cease every commercial purchase of Russian oil and gas immediately.

That distinction became important within days.

On 4 March 2022, Shell purchased a cargo of Russian crude oil.

Reuters subsequently reported that the cargo had been bought at a substantial discount.

The purchase attracted criticism, including from Ukraine’s foreign minister.

Shell initially defended the decision by referring to the need to maintain supplies of essential petroleum products.

On 8 March, the company issued a broader announcement.

It committed to ending spot purchases of Russian crude oil and outlined a phased withdrawal from other Russian hydrocarbons.

Ben van Beurden apologised for the earlier cargo purchase.

This was another significant stage in Shell’s response.

It demonstrated the difference between withdrawing from Russian equity investments and disengaging from the country’s wider oil and gas trade.

The two actions involved different commercial, contractual and logistical questions.

The March controversy also provides a revealing test of the public language used in February.

Shell had declared its decision to exit with conviction.

Days later, it was defending a Russian crude purchase as necessary for energy security.

The company subsequently acknowledged that the purchase had been a mistake.

That sequence is documented.

Whether the original decision was commercially justified is a separate question.

The detailed evidence deserves its own instalment.

Sources: Reuters — Shell’s Russian crude purchase and humanitarian fund, 5 March 2022 and Shell’s formal apology and expanded withdrawal announcement, 8 March 2022.

DOCUMENTARY FINDINGS Established facts

Shell announced its intention to withdraw from major Russian ventures and Nord Stream 2 on 28 February 2022.

The announcement followed Russia’s full-scale invasion of Ukraine on 24 February.

Shell held a 27.5% interest in Sakhalin II, a 50% interest in Salym Petroleum Development and a 50% interest in the Gydan venture.

Shell was a financier of Nord Stream 2, not an equity shareholder in Nord Stream 2 AG under the 2017 financing arrangement.

At the end of 2021, Shell reported approximately $3 billion in non-current assets associated with the Russian ventures identified in its February announcement.

The company reported approximately $700 million in adjusted earnings attributable to it from the Sakhalin Energy and Salym joint ventures during 2021.

Shell’s first-quarter 2022 accounts recorded a $1.614 billion impairment relating to Sakhalin II.

They also recorded a $1.126 billion write-down of the Nord Stream 2 loan.

Total first-quarter withdrawal-related charges were $4.235 billion before tax and $3.894 billion after tax.

The final 2022 accounts recorded net withdrawal-related charges of $4.170 billion before tax and $3.804 billion after tax.

Shell lost significant influence over Sakhalin Energy from 1 April 2022 following the resignation of its executive directors and withdrawal of managerial and technical personnel.

Russia subsequently transferred the project’s operating arrangements to a newly created Russian entity under Presidential Decree No. 416.

Shell declined to participate in that replacement company.

The company’s 2025 annual report, filed in March 2026, continued to identify unresolved Russian litigation arising from the wider consequences of its withdrawal.

Important distinctions

The February 2022 announcement was an intention to withdraw, not confirmation of an immediately completed sale.

The Sakhalin II impairment and Nord Stream 2 loan write-down concerned different forms of investment.

The financial charges were not all immediate cash expenditures.

The first-quarter and full-year withdrawal charges are not separate amounts to be added together.

Shell’s adjusted earnings excluded the identified Russia-related charges.

The Russian presidential restructuring was not a court judgment determining that Shell had acted unlawfully.

The subsequent Russian prosecutor’s allegations remain contested and are not treated as established liabilities.

Not established

The documents examined do not establish that Shell’s directors knew Russia would launch a full-scale invasion in February 2022.

They do not establish that Shell concealed internal assessments predicting the precise consequences of such an invasion.

They do not prove that the Nord Stream 2 financing arrangement was unlawful.

They do not establish that Shell’s 2022 decision extinguished every contractual or ownership right associated with its former Russian investments.

They do not establish that Shell will ultimately be liable for the sums claimed in the subsequent Moscow litigation.

EDITORIAL COMMENTARY The Russian exit was a financial reckoning with decisions made over many years

The February 2022 announcement can be understood as a response to an extraordinary geopolitical event.

Shell’s decision followed the invasion of Ukraine.

The company condemned Russia’s actions.

It announced that it would withdraw from major partnerships involving Gazprom.

Those facts are clear.

But the significance of the decision extends beyond the circumstances of February 2022.

The Sakhalin and Nord Stream 2 investments had been developed over many years.

They reflected corporate assessments concerning access to energy resources, future demand, international partnerships and the commercial importance of Russian supplies.

Those decisions were made in a world in which governments and multinational companies continued to maintain substantial commercial relationships with Russia despite repeated political controversies.

Shell was not alone.

Other major European energy companies had also invested in Russian ventures or committed financing to Nord Stream 2.

But that wider participation does not eliminate Shell’s responsibility for its own investment decisions.

For shareholders, the key question is not simply whether Shell was right to withdraw after the invasion.

It is how the company assessed the risks of its commitments before that point.

The documentary record establishes that significant warning signs existed.

Sakhalin II had experienced a politically charged ownership confrontation.

Nord Stream 2 had become the subject of regulatory disputes, sanctions and objections from European governments.

Those events did not make a full-scale invasion inevitable.

But they formed part of the environment in which Shell continued to operate.

The financial consequences ultimately recognised in 2022 demonstrate the scale of the exposure.

They also expose the limitations of a simple narrative in which Shell made a clean break with Russia on 28 February.

The actual sequence was considerably more complex.

The company announced its intention to leave.

It impaired investments.

It withdrew management personnel.

It abandoned participation in certain operating arrangements.

Russia restructured assets.

Trading and contractual relationships continued in modified forms.

Some were terminated.

Others generated disputes.

And years later, the legal consequences had still not been fully resolved.

The financial statements are the most important witnesses

Shell’s original announcement explains why the company said it was leaving.

The subsequent accounts explain what leaving cost.

The two records should be read together.

The February statement is a declaration of corporate intention.

The May results quantify the initial financial consequences.

The annual accounts document the subsequent adjustments.

The later SEC disclosures reveal the continuing legal consequences.

Taken together, they provide a more reliable historical account than any single headline.

The documentary conclusion is straightforward: Shell’s departure from Russia was announced in February 2022, but its financial and legal consequences extended far beyond that announcement.

The Sakhalin Papers have followed Shell’s Russian relationships from the struggle for control of a major energy development to their partial unwinding after a war.

The next question concerns what happened when Shell’s stated determination to withdraw encountered the immediate demands of the international oil market.

And that brings us to one of the most controversial transactions of March 2022.

SOURCE RECORD

1. Shell plc — Original Russian Withdrawal Announcement, 28 February 2022

The principal authenticated corporate document for this instalment. It identifies the ventures Shell intended to leave, records Ben van Beurden’s explanation and discloses the company’s Russian non-current assets and 2021 joint-venture earnings.

Read Shell’s original announcement

2. RoyalDutchShellPlc.com — Contemporary Publication, 28 February 2022

The Donovan–Shell archive preserved Shell’s announcement on the day it was issued. This provides a useful contemporaneous reference showing that the withdrawal was documented by the website at the time, rather than reconstructed exclusively from later reporting.

Read the original archive publication

3. Nord Stream 2 Financing Agreement, 24 April 2017

The original financing arrangements established commitments by five European energy companies of up to approximately €950 million each. Gazprom remained sole shareholder of the pipeline company.

Contemporaneous account of Shell’s financing agreement

4. Shell plc — First Quarter 2022 Operational Update, 7 April 2022

Shell estimated post-tax Russia-related impairment and additional charges of $4 billion to $5 billion and explained their anticipated treatment as identified items excluded from adjusted earnings.

Read the original Shell update

5. Shell plc — First Quarter 2022 Results, 5 May 2022

The detailed contemporary financial disclosure records the $1.614 billion Sakhalin II impairment, the $1.126 billion Nord Stream 2 loan write-down and the overall first-quarter withdrawal-related charges.

Read the full first-quarter financial announcement

6. Interfax — Shell Writes Off $3.9 Billion in Russia-Exit Losses, 5 May 2022

Contemporaneous independent reporting summarising the company’s accounting disclosures and the main financial components of its withdrawal.

Read the Interfax report

7. US Securities and Exchange Commission — Shell Annual Report and Form 20-F 2022

The principal authenticated full-year accounting record. It establishes the net 2022 withdrawal-related charges and details the consequences for Sakhalin II, Nord Stream 2 and other Russian interests.

Read the SEC filing’s Russia withdrawal note

8. Shell plc — Annual Report and Form 20-F 2025, filed 12 March 2026

Provides the subsequent authenticated corporate account of the unresolved Russian litigation, including the claim concerning approximately €1.5 billion in alleged unpaid gas deliveries and the proposed use of Sakhalin-related compensation funds.

Read the SEC filing information

9. Shell plc — Expanded Withdrawal Announcement, 8 March 2022

Records Shell’s apology for purchasing a Russian crude cargo and its decision to cease spot purchases and undertake a phased withdrawal from Russian hydrocarbons.

Read Shell’s statement of 8 March 2022

Archive disclaimer

This instalment relies principally upon authenticated Shell corporate disclosures, financial statements filed with the United States Securities and Exchange Commission, contemporaneous reporting and identified official Russian measures.

The original 28 February 2022 announcement is treated as evidence of Shell’s declared intention at that date, not as evidence that every affected transaction or contractual relationship had already been terminated.

Financial impairments are distinguished from cash payments and realised disposal proceeds.

The accounting treatment of Sakhalin II is distinguished from Shell’s financing exposure to Nord Stream 2.

The post-tax and pre-tax figures for the first quarter of 2022 are distinguished from the final reported figures for the full financial year.

No allegation is made that Shell violated sanctions through its original participation in Nord Stream 2.

No allegation is made that Shell’s directors possessed advance knowledge of Russia’s February 2022 invasion.

The subsequent Russian litigation is identified as contested proceedings. Allegations made by the Russian prosecutor are not treated as established legal findings.

The article does not characterise Shell’s Russian withdrawal as a single completed sale, nor does it assume that the recognised accounting losses extinguished every associated legal right.

Editorial commentary concerning corporate risk management is separately identified and does not represent a judicial or regulatory determination of misconduct.

Relevant factual corrections, additional primary documents and responses from Shell and other interested parties are welcome.

The website’s general disclaimer also applies.

NEXT IN THE SHELL LEAKS FILES SLF-2007-103 — The Sakhalin Papers XCIII: The Discounted Cargo — Shell’s Russian Oil Purchase, the Ukrainian Protest and the Apology That Followed

On 28 February 2022, Ben van Beurden announced that Shell intended to withdraw from its partnerships with Gazprom.

He declared that Shell was acting with conviction.

Four days later, on 4 March, the company purchased a cargo of Russian crude oil.

According to contemporaneous Reuters reporting, the cargo was acquired at a substantial discount.

The purchase attracted immediate criticism.

Ukraine’s foreign minister, Dmytro Kuleba, publicly challenged the company.

Shell initially explained its decision by referring to Europe’s need for secure supplies of petroleum products.

It subsequently promised to direct profits associated with the limited remaining Russian oil it would process towards humanitarian assistance for Ukraine.

Then, on 8 March, Shell issued an apology.

The company’s chief executive acknowledged that the purchase had been wrong.

Shell also announced a much broader programme for withdrawing from Russian oil, petroleum products, pipeline gas and LNG.

The documentary questions are unavoidable.

Why did Shell purchase Russian crude after announcing its intention to leave its major Russian partnerships?

What commercial circumstances led to the decision?

What did Shell say at the time?

What did the Ukrainian government say?

Was the purchase prohibited by sanctions?

And what changed between Shell’s initial defence of the transaction and its subsequent apology?

The next instalment will reconstruct those events using Shell’s original statements, Reuters reporting, contemporary government reactions and the company’s subsequent financial disclosures.

It will distinguish the legality of the transaction from the ethical controversy surrounding it.

The question is not whether Shell eventually apologised.

That is established.

The question is how a company that had publicly committed itself to withdrawing from major Russian partnerships came to purchase Russian crude only days later — and what the documentary record reveals about the decision.

The Sakhalin Papers continue.

THE SHELL LEAKS FILES — 29 OCTOBER 2026 was first posted on October 29, 2026 at 10:32 pm.
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Shell’s latest financial results reveal a striking contrast: a multibillion-dollar reassessment of a European biogas investment, a substantial increase in the accounting value of an LNG-related asset, and another $5 billion earmarked for share buybacks. What does this tell shareholders about the company’s energy-transition strategy?

By John Donovan — 29 October 2026

Shell plc has today announced third-quarter adjusted earnings of $10.814 billion, almost double the $5.432 billion recorded for the corresponding quarter in 2025.

Income attributable to shareholders reached $12.057 billion, while operating cash flow amounted to $21.043 billion.

These are impressive figures by almost any corporate standard.

But buried within Shell’s newly released financial statements are two disclosures that deserve particular attention.

The first concerns a $2.116 billion impairment of a European biogas asset.

The second concerns a $1.787 billion reversal of a previous impairment associated with a North American Integrated Gas asset, linked to changes in commercial terms and the final investment decision on LNG Canada Phase 2.

One investment has been written down substantially. Another has seen its recognised value increase.

The contrast raises an important question: what do Shell’s latest accounting decisions reveal about the commercial realities behind its energy-transition ambitions?

The $2.116 billion biogas write-down

On page 31 of its third-quarter financial statements, Shell discloses that it recognised total pre-tax impairments of $2.543 billion during the quarter.

Of that amount, $2.116 billion related to a European biogas asset within its Marketing business.

Shell attributes the impairment principally to a reassessment of management expectations concerning the speed of market development and the associated realisation of value.

In straightforward terms, Shell has concluded that the asset’s recoverable value is substantially lower than previously recognised.

The company has not identified the particular European biogas asset in this disclosure. It would therefore be inappropriate to attribute the charge conclusively to a named facility or subsidiary without further evidence.

That qualification does not diminish the significance of the announcement.

Biogas and renewable natural gas have featured prominently in Shell’s efforts to diversify beyond conventional fossil fuels.

Such investments have been presented as opportunities to use existing gas infrastructure while serving customers seeking lower-carbon alternatives.

Yet the latest impairment suggests that, at least for the asset concerned, commercial expectations have fallen materially.

The charge does not necessarily represent $2.116 billion in cash lost during this quarter. An impairment is an accounting recognition that an asset’s carrying value exceeds its recoverable amount.

Nevertheless, it is a substantial acknowledgement that previous assumptions about future value have changed.

Shareholders are entitled to ask how those assumptions were developed, what caused them to change, and whether further reassessments might follow.

Meanwhile, LNG Canada gains $1.787 billion in recognised value

The contrasting disclosure concerns LNG Canada.

Shell reports that impairment reversals recognised during the third quarter totalled $1.801 billion before tax.

Almost the entire amount — $1.787 billion — relates to a North American asset within its Integrated Gas business.

According to Shell, the reversal was triggered by revised commercial terms and the final investment decision taken on LNG Canada Phase 2 during the third quarter.

A reversal of an impairment means that an asset’s recoverable value has increased sufficiently to justify reversing part of an earlier write-down, subject to applicable accounting limits.

It is not equivalent to receiving $1.787 billion in cash.

Nevertheless, the financial message is significant.

While Shell has lowered the recognised value of a European biogas investment, it has increased the recognised value of an asset associated with a major LNG development.

The LNG Canada Phase 2 investment decision, taken in September 2026, is itself substantial.

According to Shell, the expansion will increase the project’s annual production capacity from 14 million tonnes to 28 million tonnes.

Shell holds a 40% interest and expects to receive nearly six million additional tonnes of LNG annually from the expansion. Commercial operations are expected to begin in the early 2030s.

That represents a long-term commitment to natural gas infrastructure.

The two accounting adjustments concern different assets, markets and commercial circumstances. They should not be treated as a direct measure of the relative profitability of biogas and LNG across Shell’s entire portfolio.

But taken together, they provide a revealing snapshot of where important commercial expectations have strengthened — and where they have weakened.

Another $5 billion for shareholders

Against this background, Shell has announced a further $5 billion share-buyback programme, expected to be completed by the fourth-quarter 2026 results announcement.

During the third quarter, shareholder distributions totalled approximately $5.3 billion, comprising $3.2 billion in share repurchases and $2.2 billion in cash dividends.

Shell also reported:

• Adjusted earnings: $10.814 billion
• Income attributable to shareholders: $12.057 billion
• Operating cash flow: $21.043 billion
• Free cash flow: $16.322 billion
• Net debt: $39.7 billion, compared with $41.8 billion at the end of the preceding quarter

These figures illustrate the continuing financial strength of Shell’s operations.

They also sharpen the debate about capital allocation.

Shareholders must assess whether management is directing capital towards investments capable of delivering sustainable long-term returns, rather than merely pursuing businesses that appear attractive under a particular political or commercial climate.

For an oil and gas company navigating the energy transition, that challenge is especially important.

This is not Shell’s first bioenergy disappointment

The latest biogas impairment should not be considered in isolation.

In its third-quarter results, Shell also refers to an impairment recognised during the equivalent quarter of 2025, principally associated with its decision not to restart construction of the planned biofuels facility at the Shell Energy and Chemicals Park Rotterdam.

That earlier episode involved a different project and different commercial considerations.

Nevertheless, both developments illustrate the financial challenges that can arise when large energy-transition investments confront changing market assumptions.

Shell is not alone in facing those challenges.

The development of lower-carbon energy markets depends on regulatory arrangements, customer demand, infrastructure, technology, competitive conditions and the availability of commercially viable returns.

But Shell’s size, resources and influence make its investment decisions particularly consequential.

When management commits billions to emerging energy businesses, shareholders are entitled to expect rigorous scrutiny of the assumptions supporting those commitments.

When those assumptions change, the reasons should be explained transparently.

The distinction between adjusted earnings and reported profits

There is another important accounting consideration.

Shell’s preferred measure of adjusted earnings excludes identified items such as certain impairments, impairment reversals, divestment gains and other adjustments.

Consequently, the headline adjusted earnings figure of $10.814 billion does not measure the full effect of every accounting development during the quarter.

The biogas charge and LNG-related reversal are reflected in the company’s statutory financial reporting, but excluded from adjusted earnings through Shell’s reconciliation process.

That approach is not inherently improper. Adjusted earnings are commonly used to compare underlying operating performance between reporting periods.

However, readers should examine both adjusted and statutory results.

A multibillion-dollar impairment remains financially meaningful even when excluded from a company’s preferred performance measure.

Equally, an impairment reversal should not be mistaken for recurring operating earnings.

What Shell’s own disclosures tell us

For readers of The Shell Leaks Files and the Independent Shell Archive, the significance of these disclosures extends beyond one quarterly reporting period.

Our historical investigations have repeatedly examined the relationship between Shell’s public representations, internal commercial assessments and subsequent developments.

The Sakhalin-2 documentary record demonstrates why it is important to preserve contemporaneous evidence of what companies expected, what actually happened, and how management explained the differences.

The present circumstances are not evidence of wrongdoing or a repetition of the Sakhalin controversy.

They are, however, another example of why the company’s original financial disclosures deserve permanent preservation and careful analysis.

The figures published on 29 October 2026 provide a verifiable reference point against which future management explanations can be assessed.

Several questions arise:

First, which European biogas asset accounts for the $2.116 billion impairment, and what changes in market expectations produced such a substantial revision?

Second, how much of the LNG-related valuation improvement arises from revised commercial arrangements, and how much from the decision to proceed with Phase 2?

Third, what do these developments imply for Shell’s remaining investments in biogas, biofuels and other lower-carbon businesses?

Fourth, how does management reconcile these commercial developments with its longer-term energy-transition strategy?

These are legitimate questions for shareholders, analysts and the wider public.

They do not imply that Shell has concealed information or breached its reporting obligations.

They arise directly from the company’s published figures.

A revealing moment in Shell’s energy transition

Shell’s third-quarter results demonstrate that the company continues to generate substantial earnings and cash flow.

They also demonstrate that the value of particular energy-transition investments can change dramatically as commercial expectations evolve.

The biogas impairment suggests significant disappointment in the anticipated economics of one European asset.

The LNG Canada impairment reversal reflects more favourable expectations for an asset associated with a major expansion of natural gas production capacity.

The contrast is noteworthy.

Shell’s energy transition cannot be judged solely by corporate statements of ambition. It must also be judged by investment decisions, asset valuations, capital expenditure and the eventual financial and environmental outcomes.

The company’s own financial reporting provides some of the most important evidence.

And today’s figures offer another reminder that the distinction between an attractive corporate narrative and a commercially successful investment can be measured in billions of dollars.

The central question is not whether Shell remains profitable. Clearly, it does. The question is whether its evolving portfolio demonstrates that the energy-transition investments promoted to shareholders are delivering the commercial results originally anticipated.

That is a question worth continuing to investigate.

Principal sources and further reading

Primary corporate disclosures

Shell plc — Third Quarter 2026 and Nine Months Unaudited Results, published 29 October 2026

The principal source for all financial figures, impairment charges, impairment reversals, portfolio developments and share repurchases discussed above. See particularly the financial statement notes on page 31.

Shell plc — Third Quarter 2026 Results Announcement

Shell’s official results announcement and investor information.

Shell — Third Quarter 2026 Update Note, 7 October 2026

Shell’s earlier trading update, providing useful context for comparing preliminary expectations with the final quarterly results.

Previous independent reporting

Shell’s Latest SEC Filing Reveals the Contradictions of Its Energy Transition: Refining Profits, Carbon Costs and Biogas Write-Downs — 8 October 2026

Earlier coverage of Shell’s third-quarter outlook and the emerging biogas impairment issue.

Shell’s Green Future Moves to China Just as Its German Battery Dream Goes Bust — 25 October 2026

Related examination of Shell’s lower-carbon investment portfolio.

Editorial note: This article is based principally on Shell plc’s unaudited third-quarter financial statements published on 29 October 2026. The accounting figures and explanations attributed to Shell are drawn from its own disclosures. Commentary concerning the implications for investment strategy and shareholders represents independent editorial analysis. This article does not allege accounting misconduct or regulatory violations. The financial results are company-issued primary disclosures; their status as a new SEC EDGAR filing has not been independently established.

Shell plc is invited to provide factual corrections or additional explanations, including identification of the European biogas asset concerned and further details of the commercial assumptions underpinning the impairment and LNG-related reversal. Any substantive response will be considered for publication.

Shell’s $10.8 Billion Profit Bonanza: A $2.1 Billion Biogas Write-Down as LNG Canada Gains $1.8 Billion in Value was first posted on October 29, 2026 at 1:06 pm.
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By John Donovan — 29 October 2026

A newly launched website, ExposeShell.com, is drawing attention to historical evidence that Shell commissioned research into the climatic consequences of burning fossil fuels as early as 1966. The archive brings together material associated with British scientist James Lovelock, Shell’s later greenhouse-effect studies and legal claims arising from Typhoon Rai in the Philippines. But how strong is the evidence, what is genuinely new, and what would make the archive most valuable to independent researchers?

In the interests of transparency and fairness, RoyalDutchShellPlc.com extends an open invitation to the ExposeShell organisers to respond to this review. We offer to publish their response in full, subject only to ordinary legal and privacy safeguards. Shell is equally welcome to respond.

Introduction: From protest slogan to documentary evidence

The launch of ExposeShell.com on 28 October 2026 represents a potentially important addition to the growing network of archives documenting the oil industry’s historical knowledge of climate change.

The initiative is associated with Fossil Free London and The Odette Case, a campaign supporting survivors of Typhoon Rai who are pursuing legal action against Shell.

The launch attracted international attention when climate campaigners staged a theatrical demonstration outside Shell’s London headquarters.

Participants dressed as 1960s oil executives, handled imitation money and acted out scenes intended to portray the suppression of inconvenient scientific evidence.

The message was unmistakable: Shell knew about the potential dangers of fossil-fuel emissions decades ago.

But a slogan, however memorable, is not a substitute for historical evidence.

The documents are what matter.

This review examines the principal records associated with ExposeShell, their historical significance, the allegations they may help investigate and the limitations of the conclusions that can presently be drawn.

One qualification is necessary. Although ExposeShell’s launch and several of its featured documents can be independently verified, direct access to the new website was unavailable during this review. This is therefore a documentary assessment of its reported collection and supporting sources, not a completed technical audit of every page or feature.

That limitation is also one reason we particularly welcome a response from the ExposeShell team, who may be able to clarify the website’s contents, organisation and future development.

1. The 1966 Lovelock report: the archive’s most significant historical evidence

The most compelling feature of the project is the research commissioned from British scientist James Lovelock.

In June 1966, Lovelock prepared a report for Shell entitled:

Combustion of Fossil Fuel: Large Scale Atmospheric Effects — Part 1: Climatic Changes.

The report examined possible connections between fossil-fuel combustion and changes in the Earth’s atmosphere and climate.

Its historical importance is substantial.

It establishes that Shell was commissioning specialist scientific research into the possible climatic consequences of fossil-fuel combustion sixty years ago.

This was long before climate change became a central issue in international politics.

The document was preserved among Lovelock’s papers at the Science Museum Library and Archives in Britain.

Investigative journalists subsequently examined the collection.

In July 2026, DeSmog published a detailed investigation drawing upon the original report and associated correspondence.

The research included concerns about worsening climatic conditions and the possible responsibility of fossil-fuel combustion.

That evidence matters because it connects the history directly to Shell’s own commissioning of research.

This is stronger than merely establishing that climate science was publicly available in 1966.

A report specifically prepared for Shell demonstrates a direct corporate connection with the subject.

However, it is important to distinguish three propositions.

First, Shell commissioned climate-related scientific research.

Second, the research contained warnings concerning potential climatic effects.

Third, Shell deliberately suppressed those warnings to deceive the public.

The first two propositions are supported by the historical documents.

The third requires further evidence concerning corporate decisions, communications and intent.

The distinction is essential to the integrity of any serious documentary archive.

Source: DeSmog — The Lovelock Papers, 29 July 2026

2. An important discovery: Lovelock’s relationship with Shell continued

The historical record extends beyond a single report in 1966.

DeSmog’s investigation identifies further correspondence and research involving Lovelock and Shell during subsequent decades.

His consultancy relationship resumed around 1980.

In March 1982, Lovelock submitted two papers identified in the surviving correspondence as Casting Pearls before Minkand Comments on CO2 in the Atmosphere.

The complete papers had not been located in the research reported by DeSmog in July 2026.

But related correspondence indicates that Shell produced internal memoranda based upon Lovelock’s work for circulation to more senior personnel.

This is a particularly promising area for further investigation.

The surviving correspondence establishes that additional scientific material existed and was considered significant enough for internal communication.

But it does not establish the complete contents of papers that have not been recovered.

A responsible archive should therefore distinguish the original documents that can be read from missing documents whose existence is evidenced only indirectly.

That approach avoids turning gaps in the surviving record into unsupported certainty.

It also creates a useful research agenda.

Locating the 1982 papers, their subsequent internal summaries and any related correspondence could materially improve understanding of how Lovelock’s advice was received within Shell.

The new archive could make a valuable contribution by maintaining a public register of such missing but identifiable documents.

3. The 1985 Shell lecture: a more explicit scientific warning

Another important discovery concerns a 1985 lecture prepared by Lovelock.

DeSmog’s July investigation reports that the document was found among his preserved papers.

Its concerns were more explicit than those expressed two decades earlier.

By 1985, Lovelock had developed the ideas associated with his Gaia hypothesis.

His understanding of the Earth as an interacting system informed his warnings concerning excessive atmospheric pollution.

The document raised the prospect of consequences on a global scale.

The historical significance is not simply that Lovelock became more concerned about climate change.

It is that his relationship with Shell provided another opportunity for the company to encounter his developing scientific thinking.

But an important evidential question remains.

A lecture prepared for Shell does not, by itself, prove exactly which directors or executives heard it, read it or relied upon it.

Those questions require attendance records, correspondence, distribution lists or other contemporaneous evidence.

The distinction between a scientist communicating a warning and a corporation adopting or rejecting that warning is fundamental.

An archive seeking to establish corporate knowledge should make such distinctions explicit.

4. The confidential 1988 report: Shell’s internal assessment becomes clearer

The 1988 Shell report entitled The Greenhouse Effect is one of the most important documents in the company’s climate history.

Unlike the earlier Lovelock research, it was an internal Shell report.

It examined the greenhouse effect and the possible consequences of increasing atmospheric concentrations of carbon dioxide and other greenhouse gases.

Its analysis discussed major changes to climate systems, sea levels, weather patterns and precipitation.

It also considered the difficulty of responding effectively once substantial warming had become unmistakable.

The report demonstrates that Shell was studying the risks of climate change internally by the late 1980s.

Its significance is reinforced by the company’s recognition of the role of fossil-fuel combustion in increasing atmospheric carbon dioxide.

Yet this is not a document newly discovered in October 2026.

The report has been publicly available through earlier investigations and documentary archives.

The Climate Investigations Center, Climate Files and other research projects have preserved or published important sections of Shell’s historical climate records.

The contribution of ExposeShell is therefore not necessarily the first discovery of every document it features.

Its potential contribution lies in bringing the evidence together, explaining its relevance and connecting it with current legal and public debates.

That distinction matters.

Discovering a document, digitising it, publishing it and placing it within an accessible research archive are different achievements.

All can be valuable, but they should be credited accurately.

Source: Climate Investigations Center — Shell Climate Documents

5. Is the evidence genuinely new?

This is one of the most important questions to ask of ExposeShell.

The available evidence suggests that the answer differs from document to document.

The Lovelock papers received significant new attention following DeSmog’s investigation in July 2026.

The 1985 lecture and correspondence surrounding the missing 1982 papers appear particularly important.

Other documents, including the 1988 greenhouse-effect report, have been publicly examined for years.

Additional Shell records concerning corporate planning, climate policy and public communications were identified by investigators including Jelmer Mommers and Vatan Hüzeir.

These discoveries are available through established documentary resources.

The Climate Files collection, for example, contains materials concerning Shell’s internal planning and its approach to environmental policy during the 1980s and 1990s.

The ExposeShell initiative should therefore be understood as part of a developing documentary ecosystem.

Its value will depend partly on how effectively it connects existing evidence with newer discoveries.

A useful archive should identify which documents were previously unpublished, which have been republished and which are included for historical context.

Clear attribution to original researchers and repositories is essential.

That practice benefits the public and protects the reliability of the historical record.

6. The central weakness in the slogan “Shell Knew”

The phrase “Shell Knew” is effective campaigning language.

As historical analysis, however, it needs definition.

What exactly is meant by knew?

Knowledge that burning fossil fuels releases carbon dioxide is not identical to knowledge of the precise future consequences of global warming.

Knowledge that climate change poses serious risks is not identical to knowledge that a particular storm will occur.

And knowledge possessed by an individual scientist or company department is not automatically evidence that every director or employee held the same understanding.

A documentary investigation should distinguish levels of knowledge.

It should identify the scientific propositions contained in each report, the confidence expressed, the recipients and any subsequent corporate response.

The 1966 and 1988 documents provide substantial evidence concerning Shell’s historical engagement with climate science.

They do not, on their own, prove every element of the wider allegations made by campaigners or litigants.

This does not diminish their importance.

It makes them more useful.

The strongest case is the one that preserves the original meaning of the evidence rather than claiming more than the documents can establish.

7. Shell’s response deserves to be included

A fair examination must also consider Shell’s published position.

Shell acknowledges the urgency of climate change and the need for a transformation of the global energy system.

It disputes claims that litigation directed at individual companies provides an effective means of achieving that transformation.

Concerning the Typhoon Odette case, Shell has challenged the attempt to attribute responsibility for a specific extreme-weather disaster to the activities of one company and its customers.

It also disputes the allegation that it possessed unique knowledge of climate change.

Shell argues that the subject has been publicly discussed and researched for decades.

The company points to its public climate communications, including its 1991 film Climate of Concern, and says it supports action to reduce emissions.

These statements do not invalidate the original historical reports.

Nor do the original reports automatically disprove Shell’s entire defence.

The disagreement concerns the interpretation and legal consequences of historical knowledge, corporate conduct and emissions.

Readers should be able to examine both the underlying documents and Shell’s response.

Primary source: Shell — What Kind of Climate Lawsuits Have Been Filed Against Shell?

8. The Typhoon Odette litigation: why historical documents could matter in court

The ExposeShell project is connected with litigation involving survivors of Typhoon Rai, known locally as Typhoon Odette.

The storm struck the Philippines in December 2021.

It caused extensive destruction and loss of life.

Claimants represented by Hausfeld have brought proceedings against Shell in England.

They argue that greenhouse-gas emissions associated with Shell’s historical activities contributed to climate change and consequently to the losses suffered during the typhoon.

The claim involves difficult questions of scientific attribution and legal causation.

Climate science can examine how human-caused warming changes the probability or severity of certain extreme weather events.

But establishing legal responsibility for particular losses requires additional findings under the applicable law.

Historical evidence concerning Shell’s scientific knowledge may be relevant to questions about foreseeability, corporate conduct and responsibility.

It does not automatically resolve the causation question.

Nor does the existence of the lawsuit establish that the claimants will succeed.

The court must consider the evidence and competing legal arguments.

The historical climate documents may be important.

But they should not be described as a judicial determination of liability before the court has reached such a conclusion.

Source: Hausfeld — Typhoon Odette Survivors’ Climate Damages Claim Against Shell

9. The archive’s potential research value

ExposeShell’s underlying concept has substantial merit.

Historical corporate documents are often scattered among museums, academic collections, litigation records, investigative websites and archived media reports.

Researchers may know that a particular report exists without knowing where the complete document can be found.

A dedicated archive can reduce those difficulties.

It can also make documentary evidence accessible to readers who lack specialist knowledge of the energy industry.

But its usefulness depends upon transparency.

For every important document, the archive should ideally provide the original date, author, recipient, title, original repository, document reference and complete source.

Where documents have been obtained by journalists or researchers, that contribution should be acknowledged.

Where a report is incomplete, the missing sections should be identified.

Where the provenance is uncertain, the uncertainty should be disclosed.

A modern archive should also allow documents to be downloaded and searched.

For long-term research, individual files should have stable identifiers and permanent links.

The underlying content should remain accessible independently of interactive graphics or promotional material.

These are standards against which ExposeShell can be assessed as it develops.

The publicly available descriptions establish that the initiative is intended to make historical evidence more accessible.

A completed technical examination of the live website would still be needed to determine how fully it currently meets those standards.

10. Why ExposeShell and the Donovan–Shell archive could complement one another

There is considerable potential for cooperation between ExposeShell and the independent Donovan–Shell documentary archive.

The two projects approach Shell’s history from different directions.

ExposeShell concentrates on climate science, corporate knowledge and the relationship between historical evidence and contemporary climate litigation.

The Donovan–Shell archive covers a much wider range of subjects.

These include the company’s historical corporate conduct, internal communications, legal disputes, whistleblower disclosures, environmental controversies, Sakhalin-2, Nord Stream 2 and security-related activities.

Our archive also contains extensive contemporaneous reporting and correspondence spanning several decades.

The projects therefore have overlapping interests but different strengths.

That creates opportunities for cross-referencing.

For example, historical Shell climate documents may be relevant to later company statements concerning environmental responsibility.

Similarly, records of corporate communications and public-relations practices can help researchers examine how Shell presented environmental issues over time.

But cooperation should not mean merging distinct allegations or adopting each other’s conclusions without verification.

The appropriate relationship would be documentary.

Each archive could identify original sources held by the other.

Researchers could follow cross-references between related documents.

Corrections and disputed interpretations could be recorded transparently.

This would be valuable for conventional research and increasingly important for artificial-intelligence systems.

Search engines and AI models can sometimes repeat an unsupported claim simply because it has appeared across several websites.

Repetition is not independent corroboration.

Two archives linking to the same original document should be recognised as two routes to one source, not two independent pieces of evidence.

A shared commitment to provenance would therefore be especially important.

11. The issue of long-term preservation

The launch of an online archive is an achievement.

Its long-term survival is a different challenge.

Campaign websites may be created for particular events, lawsuits or public-awareness initiatives.

Their content may remain valuable long after the original campaign has ended.

The risk is that hosting arrangements change, funding disappears or websites are redesigned in ways that break older links.

Documents may become inaccessible even though they were originally published with the intention of preserving them.

For a collection dealing with events dating back sixty years, durability is essential.

Copies of historically important records should ideally be preserved in more than one location.

Original files should be retained.

Metadata should accompany the documents.

And important material should not depend entirely upon a single commercial platform or interactive viewer.

The Science Museum’s preservation of Lovelock’s papers demonstrates the value of institutional archives.

The work of investigative journalists demonstrates the value of making those records publicly accessible.

A durable digital archive should attempt to combine both approaches.

The goal should be not merely to expose documents today, but to ensure that researchers can still examine them decades from now.

Documentary findings Established

Shell commissioned climate-related research from James Lovelock during the 1960s.

The surviving material includes a report dated June 1966.

Additional Lovelock correspondence and lecture material has been identified in the Science Museum’s collections.

Shell produced a confidential greenhouse-effect report in 1988.

Several important Shell climate documents were published by investigative researchers before the launch of ExposeShell.

ExposeShell was launched in October 2026 to make historical climate-related material accessible and support public understanding of the issues.

The initiative is associated with campaigns concerning climate responsibility and the Typhoon Odette litigation.

Shell disputes the claimants’ allegations and maintains that climate change has been the subject of public scientific discussion for decades.

Not established

The historical documents do not, without additional evidence, establish that every Shell director possessed identical scientific knowledge.

They do not prove that Shell deliberately destroyed the original Lovelock report.

They do not establish that all internal confidentiality arrangements were intended to deceive the public.

They do not determine Shell’s liability for Typhoon Rai.

Nor has this review independently verified the complete contents, navigational features, accessibility, document count or technical durability of ExposeShell’s live website.

Editorial conclusion: The real value of exposing Shell

The importance of ExposeShell lies in its potential to make original historical evidence more accessible.

The 1966 Lovelock report is significant.

The later correspondence and 1985 lecture are significant.

The 1988 greenhouse-effect report is significant.

Together, these documents help reconstruct the development of scientific understanding within and around Shell.

But their importance should not be exaggerated into claims that the documents themselves cannot support.

A successful documentary archive should allow readers to examine the evidence independently of the campaign through which it was publicised.

It should also distinguish established scientific knowledge from the changing levels of certainty associated with particular forecasts.

Above all, it should preserve the difference between a historical document and an allegation made about that document.

ExposeShell has the potential to become an important resource for researchers examining the history of corporate climate knowledge.

Its relationship with existing documentary collections should be complementary rather than competitive.

The question is not which website can make the strongest accusation.

The question is which collection can provide the clearest access to authenticated evidence.

For RoyalDutchShellPlc.com, that principle is familiar.

Our long-running archive has repeatedly demonstrated the importance of preserving original correspondence, corporate documents, court records and contemporary reporting.

Those records may support criticism of Shell.

They may also correct exaggerations or misunderstandings.

Both outcomes strengthen the historical record.

ExposeShell deserves serious attention because the scientific documents behind it are real and historically important.

Its enduring value will depend upon how carefully those documents are presented, attributed, contextualised and preserved.

If it achieves those aims, the archive could become a useful resource not only for campaigners and litigants, but for shareholders, historians, journalists and future generations of researchers.

The appropriate response from an independent archive is therefore to welcome the publication of historical evidence, examine it critically and offer cooperation where doing so improves public access to the original records.

The documents should decide. Not the slogan, not the company, and not the archive that publishes them.

An open invitation to the ExposeShell team

RoyalDutchShellPlc.com warmly invites the organisers of ExposeShell to respond to this review.

We recognise the importance of preserving and making accessible historical documents concerning Shell’s knowledge of climate change.

We also recognise the substantial research undertaken by the journalists, scientists, archivists and campaigners responsible for bringing these records into the public domain.

Our review has identified several subjects on which further information would be particularly welcome.

These include the provenance of documents published through ExposeShell, identification of material being made publicly available for the first time, the completeness of the current collection and arrangements for its long-term preservation.

We would also welcome clarification concerning documents whose existence has been established through correspondence but whose complete contents have not yet been recovered.

Of particular interest are the two papers reportedly supplied by James Lovelock in 1982 and the related Shell internal memoranda.

If the ExposeShell team can provide additional information about those records, it would be a valuable contribution to the historical record.

We would equally welcome corrections to any factual inaccuracies, omissions or misunderstandings in our assessment.

We undertake to publish a substantive response from ExposeShell in full and without editorial alteration, subject only to ordinary legal and privacy safeguards.

Any necessary editorial qualifications would be clearly identified separately.

Our purpose is not to compete with ExposeShell but to encourage the preservation, verification and accessibility of important historical evidence.

We would also welcome discussion of possible cooperation between ExposeShell and the independent Donovan–Shell documentary archive.

Such cooperation might include reciprocal links, cross-referencing of original documents, identification of previously unpublished material and sharing information about records held in other collections.

The two archives need not agree upon every interpretation.

Indeed, independent examination is most valuable when differing interpretations can be tested against the same original sources.

Our common interest should be the survival and accessibility of the documents.

The ExposeShell team is welcome to have its say, in its own words, on RoyalDutchShellPlc.com.

An equivalent invitation to Shell plc

In the same spirit of fairness, we also invite Shell plc to respond to this article.

We would welcome any factual corrections, relevant historical records or clarification concerning the company’s commissioning, receipt, distribution and subsequent use of the Lovelock research and other early climate studies.

Shell is equally welcome to provide a substantive response for publication, subject to the same ordinary legal and privacy safeguards.

Our intention is to maintain an accessible record in which documentary evidence, corporate explanations and independent analysis can be considered together.

The invitation to both parties is made openly and in good faith.

The objective is not to establish which organisation can advance the most persuasive slogan, but which conclusions can be supported by authenticated evidence.

Principal sources

1. ExposeShell — New Historical Climate Archive — The initiative under review; direct technical inspection was not available during this assessment.
2. DeSmog — Interactive Archive Shares Secrets of Shell’s Early Climate Research, 28 October 2026 — Reporting on the launch, organisers and litigation connection.
3. DeSmog — The Lovelock Papers, 29 July 2026 — Investigation of Lovelock’s original archival papers and scientific warnings.
4. Climate Investigations Center — Shell Climate Documents — Established collection of Shell reports and documentary references.
5. Climate Files — New Shell Documents from the Dirty Pearls Investigation — Additional historical Shell records concerning climate research and corporate planning.
6. Shell — Official Position on Climate Litigation — Shell’s published response to climate-related legal claims, including the Typhoon Odette proceedings.
7. Hausfeld — Typhoon Odette Survivors’ Claim Against Shell — The claimants’ legal representatives explain the case and allegations.

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The existence of early Shell climate research does not, without additional evidence, establish every allegation made concerning the company’s historical intentions or conduct.

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ExposeShell Under the Microscope: A New Climate Archive, Six Decades of Documents and the Evidence Behind “Shell Knew” was first posted on October 29, 2026 at 11:01 am.
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