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By John Donovan: Monday 19 June 2017

It is interesting, in view of subsequent events, to reflect back on an “Investigations Case Manager” job Shell advertised a decade ago.


The successful candidate for this role will provide specialist advice, awareness training, information and expert investigative resources to all Group companies worldwide on practices which conflict with Shell Group Business Principles. These include fraud, contract corruption (illegal information brokering), bribery, money-laundering and organised crime.

Something must have gone terribly amiss with these lofty plans given the series of subsequent Shell corruption scandals culminating in Shell recently admitting dealings with a money launderer in the notorious Nigerian OPL 245 deal.

In 2010, in an unrelated matter, Shell was ordered to pay $48m (£29.4m) in civil and criminal fines over its contractor’s (Panalpina) involvement in bribing Nigerian customs officials.

Panalpina clients, including Shell, admitted they “approved of or condoned the payment of bribes on their behalf in Nigeria and falsely recorded the bribe payments made on their behalf as legitimate business expenses in their corporate books, records and accounts”.

Some of the above is extracted from a Daily Telegraph article: Shell to pay $48m Nigerian bribe fine.

In Ireland, Shell contractors (OSSL) working on the controversial Corrib Gas Project have admitted in court room testimony given under oath, distributing bribes on behalf of Shell. Shell Ireland CEO Michael Crothers was promoted to Country Chair of Shell Canada after covering-up Shell’s Irish misdeeds.

It seems that the top brass at Shell only pay lip service to claimed business principles and everything else is PR window dressing, including advertising for experts supposed to counter or stop such criminal activity.


Investigations Case Manager (x2) Job ID: E8021

Location: Den Haag (The Hague), Netherlands

Shell Central Finance (CF) provides a range of professional services, advice and products to Shell companies on a global basis. This support encompasses everything from management and financial accounting, consultancy and business controls through to Mergers & Acquisitions, insurance and treasury operations.

The importance of compliance in today’s climate means that our Internal Audit department is integral to our success. As well as carrying out audits for our businesses and functions, it helps to streamline our operations, engineer business processes and facilitate more open communication.

The successful candidate for this role will provide specialist advice, awareness training, information and expert investigative resources to all Group companies worldwide on practices which conflict with Shell Group Business Principles. These include fraud, contract corruption (illegal information brokering), bribery, money-laundering and organised crime.


As one of our Investigations Case Managers, you’ll identify and advise on the implementation of improved controls, the coordination and governance of Business Integrity across the Group, and maintain a cross-business integrity network. You’ll undertake the role of Regional Case Manager on behalf of the Ethics and Compliance Office, including regular contact and briefings with Business Compliance Officers.

Taking responsibility for assessing integrity issues that are forwarded to the department, identifying the appropriate resources, managing the assigned investigation teams, and reporting to the Business on conclusion, you’ll be required to manage 100+ investigations every year. 

Depending on the size and complexity of the investigation, you’ll brief and manage investigation teams of up to six people. These teams are made up of individuals from different Shell companies, external suppliers and external counsel.

You also have the following additional responsibilities:

• Acting as Group Subject Matter expert and advisor on investigations, and taking responsibility for the protection and risk assessment of Whistle-blowers while considering the physical, psychological and legal risks involved

• Developing materials and organising and delivering an Investigation Skills course to 24+ international staff a year

• Providing awareness presentations to audiences ranging from 10-70 staff

• Coordinating the activities of nominated Business Integrity representatives around the Group to maintain a cohesive network and approach to the management of Business Integrity

• Facilitating the sharing of relevant information

• Taking accountability for the advice, expertise and work product provided by Business Integrity Department re investigation activities

• Taking accountability for compliance to internal and external legal policies during internal investigations.

Your principal accountabilities will be as follows:

• Providing regular communication and investigative briefings to senior managers within Shell on highly sensitive business issues. This involves investigating entities, collating and analysing data, writing reports, presenting findings and proposing pragmatic and robust business solutions

• Taking accountability for the management of integrity related investigations as required by Shell Internal Audit, managers in the Group businesses, as a result of Whistle-blowing submissions

• Providing Subject Matter Expert advice to different parts of the business upon request

• Ensuring confidentiality in relation to sensitive data with potential Group impact on a daily basis

You’ll also have a number of key challenges, including:

• Prioritising the demand for BID Services with the added difficulties of balancing the requirements of international/cross border/cross time zone cases

• Managing investigations staff and resources in difficult environments and countries
• Understanding the different business areas and having the ability to rapidly assimilate facts and knowledge of commercial practices in a constantly changing business


With highly effective communication and interviewing skills, and the ability to communicate well with senior management, you’ll be an expert operator of specialist investigation software.

With first-class prioritisation skills, you’ll be effective at influencing without authority, and be passionate upholding moral and ethical behaviour within the company.

You’ll have excellent presentation, training and facilitation skills, and capable of providing expert assistance to those investigations that are particularly sensitive to the Group. With specialist knowledge and experience of crime, illegal activities, the management of Whistle-blowers and Contracting & Procurement irregularities, you’ll have the ability to transfer specialist knowledge into useful business input.

Capable of assessing trends of fraudulent crime and its impact on Shell around the world, you’ll have expert knowledge of Shell policies relevant to Business Principles and the investigation of breaches including Shell disciplinary procedures.

With excellent knowledge of current legislation concerning corporate investigations and external reporting requirements, you should also have good diplomatic skills and awareness of Diversity and Inclusiveness issues.

Application Deadline: Wednesday, February 07, 2007

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