THE SHELL LEAKS FILES: 26 SEPTEMBER 2026
SLF-2007-069
The Sakhalin Papers LIX: The 120-Day Test — When Shell’s $20 Billion Project Was Put Out for Public Judgment
In December 2005, the European Bank for Reconstruction and Development decided that Sakhalin II’s environmental and social documentation was sufficiently developed to enter formal public consultation. That was not project approval and it was not a loan decision. During the following 120 days, critics challenged the project in London, Moscow, Sakhalin and Hokkaido over whales, salmon rivers, seismic risk, oil-spill preparedness and consultation itself. Sakhalin Energy maintained that it was complying with Russian law and improving its environmental controls. Then, before the financing question could be resolved, the argument changed character. Russian regulators moved against a crucial environmental approval, Gazprom was seeking entry into the project, and EBRD said the resulting legal uncertainty prevented it from progressing its financing decision.
Archive reference: SLF-2007-069
Collection: The Sakhalin Papers
Principal institutional record: European Bank for Reconstruction and Development Sakhalin II records and Independent Recourse Mechanism file
Authenticated corporate record: The Shell Sustainability Report 2006
Contemporaneous reporting: AFP, Oil & Gas Journal, RIA Novosti, The Guardian, El País
Campaign submissions: WWF, Friends of the Earth, The Corner House and Friends of the Earth Japan
Later judicial context: Export Credits Guarantee Department v Friends of the Earth [2008] EWHC 638 (Admin)
Evidence standard: EBRD determinations are distinguished from campaign-group interpretations of them. Sakhalin Energy statements are attributed to the company. Russian environmental allegations are distinguished from contemporaneous claims that regulatory action was being used to influence Gazprom’s entry into the project. No court identified in this file determined that the 2006 Russian enforcement campaign was either fabricated or politically motivated.
Shell Singapore has been formally charged over two oil pollution incidents at its Pulau Bukom refinery, including allegations that the company failed to report the discharges to Singapore authorities without delay.
In a move that has left the entire public relations industry gasping for air (and possibly a stiff drink), Shell has once again turned to the wizards of spin at MSQ Partners. The London-based group, which joined Shell’s global agency roster back in 2022 and has been gamely polishing the oil major’s image ever since, now faces what industry insiders are calling “the Mount Everest of reputation management – if Everest were made of crude oil, blood, and decades of awkward court documents.”
The following is understood to be an internal document circulated to new starters on MSQ’s Shell business. We cannot verify its authenticity, but we also cannot stop laughing.
LONDON — In a move hailed by branding experts as “the ultimate stress test for human optimism,” marketing and technology group 
