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Jyoti Munsiff: Shell’s Chief Ethics and Compliance Officer: analogous to putting a fox in charge of a hen house.


Dear Alfred

The message below was found on the Shell Web today. I have been with Shell for quite some years, but this beats everything. They are now mixing up the General Business Principles and Ethics (which are from the good old days and perfectly adequate today) with Legal Compliance.
In the past it was very simple: you behave decently and all was well. It was obvious to all one had to remain within the law. I understand that the enormous mountain of regulations and controls rolled out by the various Authorities needs sharpening up some internal processes so one does not forget to submit some document. Otherwise the shysters will get you on a technicality.

But here something else is happening: the management has transformed the organisation over the last 10 years or so. Herkstroter started it, Moody-Stuart lost the grip on the transformation and the evil Watts got rich and destroyed the name of Shell and probably the company itself as well.

It was done very effectively by rewarding promise rather than performance. Remember the expression of ‘Overpromise and Underdelivery’? And so he left a basically spineless (but very clever) management behind that is trying to pick up the pieces. All the while ensuring not loosing out on the financial rewards themselves. And then you get nonsense like this. Or is it in preparation of upcoming lawsuits in the USA where they can say ‘but we took all necessary steps’ etc etc?

I know of no whistle blower in history that was rewarded for his or her brave actions. Yes, there always is applause from the politicians, the people who felt wronged by whatever system the whistle was blown on, the junior staff who did not know how to bring the issues to the table of the top and of course the Press who always is in for a scandal. But just look at all the whistleblowers a year or so after their act? I know of none that has been rewarded. On the contrary, they all have personally lost out! The name of Dr Huong springs to mind.

And in a company like Shell you have a lot of very clever people. They know what will happen so they lay low and put up with it. Shell Nigeria (where more defalcations where happening than in the rest of the whole Shell group combined) also set up a formal whistle blowers line many years ago. I do not think it led to anything. It might have caught some small fry but the real bad stuff simply was untouched.

So, I will not be using the Shell line, your site is better because there anonymity is guaranteed. I hope more Shell employees will take up this possibility!

PS. I thought you might also be interested in the person appointed as our Chief Ethics and Compliance Officer as I noticed on your website that you have had some personal dealings with Jyoti Munsiff at some point? From what I read her appointment seems analogous to putting a fox in charge of a hen house.


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Jyoti Munsiff

Compliance message for all staff


We all enter 2006 keen to do everything possible to ensure that the Shell name is not damaged by anything that we might do. Our Group’s reputation is based on our individual commitment to the core values of honesty, integrity and respect for people. It is these core values which underpin the Shell General Business Principles.

We all enter 2006 keen to do everything possible to ensure that the Shell name is not damaged by anything that we might do. Our Group’s reputation is based on our individual commitment to the core values of honesty, integrity and respect for people. It is these core values which underpin the Shell General Business Principles.

To continue to be regarded as a great group of companies, we must ensure compliance not only with the laws of the countries in which we operate but also with the ethical standards expected of a leading global organisation. Compliance with the law is the foundation of our ‘license to operate’ and this has to be achieved in accordance with both the spirit and the letter of our General Business Principles.

In seeking to establish a global Shell Compliance Programme, I would like to share with you some achievements and our plans for 2006.
From the 30th December 2005, we have established a global compliance help-line hosted by a third party: available 24 hours a day, 365 days a year and with access to interpreters for over 150 languages.

This will enable employees and third parties with whom we work to raise ethics and compliance concerns and report incidents of non-compliance in confidence and without fear of reprisal. Roll-out to individual countries will be phased over the first few months of 2006 following local consultation and advice. In the meantime, you can find details on how to access the global helpline via “Report your Concerns” on the Ethics and Compliance website – see the link below.

While we all know that our General Business Principles provide the foundation for our activities, we are intending to develop and roll-out a global Code of Conduct. This will assist each of us by translating the General Business Principles into a topic-based code which can be easily incorporated into our daily working lives and help to resolve some of the dilemmas which we might face.

During 2005 all senior management from Letter Category up to and including the Executive Committee completed mandatory training on legislation imposing compliance obligations on companies and a web-based training module on the OECD Guidelines on Bribery and Corruption.

To further assist each employee to appreciate key legislation, which affects us all, and to understand and implement the standards of behaviour expected of us, a global training programme will be launched in 2006. Over a period of time, all Shell employees will be able to benefit from completing a series of tailored training modules.

To help you understand the compliance framework within Shell and how specifically defined compliance roles will operate and interact with each other, together with their reporting responsibilities, please access the Ethics and Compliance website at and click on Shell Compliance Programme and Contacts.

I am pleased to announce that Business Compliance Officers have been appointed for each of our Businesses, ready to start work during the next couple of months. They are Carlos Desmet for EP, Roy Kretzen for Downstream, Jan Pars for GP, and ChiChi Nwosu for Renewables & Hydrogen. They have an important job to do in developing and maintaining a focused compliance programme for their Businesses, in which they will receive wholehearted support from their management. They are available to each of you in the event that you wish to discuss a matter which falls within the Compliance and Ethics area.

With these developments, I feel confident that we go into 2006 well placed to establish an effective global Compliance Programme for Shell companies. In these days, legal and ethical compliance is not optional. Moreover, it is not a spectator sport – everybody who receives this message has his or her part to play. Great companies are built on trust and integrity and this requires constant vigilance and an environment where we are supportive of each other yet intolerant of those who undermine our combined efforts to protect the Shell reputation.

We will be making more announcements about the compliance training programme and global helpline over the next few weeks. Please look out for our e-mails and keep checking the Ethics and Compliance website for more information.

On behalf of the Global Ethics and Compliance Office may I wish you all the best in your endeavours during 2006 on behalf of this great group of companies.

Jyoti Munsiff SCO
Chief Ethics and Compliance Officer
Royal Dutch Shell plc
Shell Centre, London SE1 7NA
Tel: +44 020 7934 3080 Fax: +44 20 7934 5140 Mobile: +44 7768 993 600
Company Number: 4366849


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