THE SHELL LEAKS FILES: 12 OCTOBER 2026
SLF-2007-085
The Sakhalin Papers LXXV: From Sakhalin to the Baltic — Shell Joins Gazprom’s Nord Stream 2 Project as Europe Divides
On 4 September 2015, Royal Dutch Shell chief executive Ben van Beurden joined Gazprom chairman Alexey Miller and four other European energy companies in signing an agreement to develop Nord Stream 2. The proposed pipelines would double the capacity of the existing Baltic Sea route for Russian gas exports to Germany. Shell described the project as necessary for Europe’s future energy needs. Six days later, the Slovak prime minister publicly condemned the agreement as a betrayal of Ukraine and Slovakia. Within weeks, the European Parliament was raising concerns about energy dependence, security and the political consequences of bypassing established transit countries. The authenticated corporate announcements, contemporary journalism, parliamentary records and subsequent court proceedings reveal how a project promoted as commercial infrastructure became a major geopolitical controversy.
Archive reference: SLF-2007-085
Publication date: 12 October 2026
Collection: The Sakhalin Papers — Shell, Gazprom and Russia
Principal authenticated records: Gazprom and OMV joint corporate announcement, 4 September 2015; European Parliament briefing, 1 October 2015; US Treasury sanctions announcement, 12 September 2014; EU regulatory and judicial records.
Contemporaneous reporting: Reuters, 18 June and 4 September 2015; Associated Press, 10 September 2015; Euractiv, 10 September 2015; Agence Europe, June and October 2015.
Judicial context: Court of Justice of the European Union, Nord Stream 2 AG v European Parliament and Council, Case C-348/20 P, judgment of 12 July 2022. Used solely to distinguish the original 2015 shareholding proposal from the ownership and financing arrangements subsequently adopted.
Evidence standard: Corporate announcements establish what was signed and publicly proposed, not whether every anticipated share acquisition or investment subsequently occurred. Contemporary political statements are attributed to their speakers. Subsequent judicial findings are identified separately from the events of 2015. No allegation is made that Shell violated sanctions or that the September agreement was unlawful.
Introduction: Shell’s Russian ambitions cross Europe
The previous instalment, The Shell Leaks Files — 11 October 2026, examined the expanding strategic relationship between Shell and Gazprom.
On 18 June 2015, Ben van Beurden and Alexey Miller had signed agreements concerning their wider cooperation and the proposed third LNG production train at Sakhalin II.
The Sakhalin expansion depended upon additional gas from Gazprom-controlled resources.
But on 7 August 2015, the United States imposed export-control restrictions specifically targeting the Yuzhno-Kirinskoye field, an important potential source of that gas.
Those restrictions complicated the commercial assumptions underlying the expansion.
Yet Shell’s ambitions in Russia were not limited to Sakhalin.
At the same St Petersburg forum in June, Shell had also participated in discussions about constructing additional gas-export infrastructure across the Baltic Sea.
That proposal was considerably more than an extension of an existing commercial partnership.
It envisaged two new offshore pipelines delivering Russian gas directly to Germany.
The additional capacity would equal that of the original Nord Stream system.
And it would provide Gazprom with another major route to European customers without passing through Ukraine.
On 4 September 2015, the proposal advanced from preliminary understandings to a shareholders’ agreement.
Shell’s chief executive personally signed it.
The political reaction was immediate.
1. The authenticated record: 4 September 2015
The most important primary document is Gazprom’s official announcement issued at 08:00 on 4 September 2015.
Its title was:
“Gazprom, BASF, E.ON, ENGIE, OMV and Shell sign Shareholders Agreement on Nord Stream 2 project.”
The signing took place at the Eastern Economic Forum in Vladivostok, Russia.
The participants were:
- Alexey Miller — Gazprom.
- Kurt Bock — BASF.
- Klaus Schäfer — E.ON.
- Pierre Chareyre — ENGIE.
- Rainer Seele — OMV.
- Ben van Beurden — Royal Dutch Shell.
The announcement confirmed that the companies had signed a shareholders’ agreement concerning the construction of Nord Stream 2.
It identified New European Pipeline AG as the proposed project vehicle.
The plan envisaged two offshore pipeline strings running from Russia to Germany across the Baltic Sea.
Their combined annual transport capacity would be approximately 55 billion cubic metres of natural gas.
Gazprom presented the project as an expansion of the existing Nord Stream system, applying experience acquired during its development and operation.
The announcement is an authenticated corporate record.
It identifies the signatories, the proposed structure and the commercial purpose of the agreement. Gazprom
Importantly, the announcement was independently reproduced by one of the Western participants.
OMV published its own official release on the same day.
The two records agree on the principal facts.
Primary source: OMV — Shareholders’ Agreement on Nord Stream 2, 4 September 2015
This provides strong documentary confirmation of Shell’s participation.
There is no need to rely on anonymous sources or retrospective recollections to establish that van Beurden signed the agreement.
2. Shell’s proposed 10 per cent interest
The September agreement set out a proposed ownership structure.
Gazprom would hold 51 per cent.
E.ON, Shell, OMV and BASF/Wintershall would each hold 10 per cent.
ENGIE would hold the remaining 9 per cent.
Gazprom would therefore retain majority control.
The Western partners collectively expected to hold 49 per cent.
For Shell, the proposed 10 per cent participation represented a potentially significant investment in European gas infrastructure.
But there is a crucial documentary distinction.
The September agreement specified intended shareholdings. It does not, by itself, prove that Shell subsequently acquired the proposed equity interest.
That distinction is particularly important because the project’s ownership arrangements changed.
Later regulatory objections prevented the original Western participation structure from being completed as planned.
Shell ultimately became a lender rather than a shareholder in the project company.
The later court record confirms that Gazprom remained the sole shareholder of Nord Stream 2 AG, with Western companies, including Shell, contributing through financing arrangements.
That subsequent development must not be projected backwards onto September 2015.
At the time of the Vladivostok signing, the publicly announced intention was for Shell to acquire a 10 per cent interest.
The fact of the agreement is established.
Completion of the proposed share acquisition is a separate question. Italaw
3. What the new pipeline would do
The original Nord Stream project consisted of two offshore pipelines connecting Russia and Germany beneath the Baltic Sea.
The first began operating in 2011.
The second followed in 2012.
Together, they provided approximately 55 billion cubic metres of annual transport capacity.
Nord Stream 2 proposed to add another two pipelines.
If completed and fully utilised, the four lines would provide a combined nominal capacity of approximately 110 billion cubic metres annually.
That was a major potential expansion of Russia’s direct gas-export infrastructure to Germany.
The route also had a fundamental geographical characteristic.
It bypassed Ukraine.
This was commercially significant because Ukraine had historically been a major transit country for Russian gas entering European markets.
Gas transported through Ukraine also passed through infrastructure in neighbouring countries, including Slovakia.
Transit arrangements generated revenue and gave those countries an important role in Europe’s energy system.
The Baltic route offered Gazprom an alternative.
It could transport gas directly to Germany without using Ukrainian transit infrastructure.
That possibility was central to the controversy.
It is important, however, to distinguish pipeline capacity from actual deliveries.
An additional 55 billion cubic metres of capacity did not automatically mean an additional 55 billion cubic metres of European gas consumption.
Nor did the agreement establish that all existing transit volumes would immediately be transferred away from Ukraine.
Those outcomes depended upon future production, contracts, market demand, regulatory requirements and operational decisions.
The authenticated agreement established the intended infrastructure capacity.
Its eventual commercial utilisation remained uncertain. OMV
4. Ben van Beurden’s public justification
Shell’s chief executive did not leave his reasons for supporting the project entirely to speculation.
The joint corporate announcement included his statement.
Van Beurden argued that natural gas would remain an important component of Europe’s energy supply for many years.
He pointed to declining European domestic gas production.
In his view, additional import infrastructure would be needed to meet future demand.
This was a recognisable commercial argument.
Natural gas played an important role in European electricity generation, industry and heating.
Domestic production in several mature European gas provinces was declining.
Additional imports could help replace that lost production.
Shell was also a major participant in international gas markets and LNG production.
The commercial logic behind investment in gas infrastructure was therefore consistent with the company’s wider business strategy.
But the argument contained an important omission.
Van Beurden addressed Europe’s anticipated demand for natural gas.
He did not, in the quoted statement, explain why meeting that demand specifically required additional dependence upon infrastructure transporting gas from Russia.
There is a distinction between needing gas and needing more Russian pipeline capacity.
Europe could pursue additional imports through several routes and from different suppliers.
Those alternatives had different costs, capabilities and limitations.
The September corporate announcement presented Nord Stream 2 as an answer to future European gas demand.
It did not independently establish that Nord Stream 2 was the only available or most secure solution.
Source: The joint corporate announcement, including van Beurden’s statement
5. Gazprom’s argument: a more reliable route
Gazprom’s public position was equally clear.
Alexey Miller welcomed the proposed doubling of the Baltic Sea route.
He argued that declining European domestic gas production would create demand for additional imports.
He also stressed the importance of having major international energy companies participate.
For Gazprom, Western corporate involvement offered several advantages.
It provided prospective investment partners.
It offered commercial and technical expertise.
And it demonstrated that important European energy companies remained willing to undertake substantial business with Gazprom despite the deterioration in relations between Russia and the West.
Gazprom presented the project as strengthening the security and reliability of European gas supplies.
But the meaning of security was contested.
For Gazprom, an offshore route bypassing established transit countries could reduce exposure to disputes involving those countries.
For Ukraine and Slovakia, the same route could weaken their economic and strategic positions.
For critics within the European Union, it could increase reliance upon a single external gas supplier.
The disagreement therefore concerned competing definitions of energy security.
Security of a particular transport route was not necessarily the same as security through diversification of suppliers.
That distinction would become central to the European political debate.
6. The project had already been prepared in June
The September shareholders’ agreement did not emerge without warning.
On 18 June 2015, Shell, Gazprom, E.ON and OMV had signed memoranda concerning additional gas-transmission infrastructure across the Baltic Sea.
The proposal involved the same additional annual capacity of approximately 55 billion cubic metres.
Contemporary Reuters reporting identified the political context immediately.
Russia was facing Western sanctions over Ukraine.
Gazprom was seeking additional routes to European customers that did not depend upon Ukrainian transit.
The June memorandum demonstrated corporate interest.
The September agreement moved the project forward by specifying a proposed ownership structure and implementation vehicle.
That progression is important.
A memorandum of intent indicates the parties’ willingness to explore a project.
A shareholders’ agreement represents a more developed contractual framework.
But neither should automatically be treated as proof that construction was inevitable.
The project still required financing arrangements, regulatory approvals, technical preparations and commercial commitments.
The September agreement therefore marked a significant development without resolving every obstacle. La Tribune
7. The political contradiction: sanctions and new investment
The timing made the agreement unusually sensitive.
Russia had annexed Crimea in March 2014.
Western governments had introduced sanctions.
Those sanctions were expanded later in 2014.
In September of that year, Washington had imposed restrictions affecting certain Russian deepwater, Arctic offshore and shale-oil activities.
The European Union had introduced its own measures affecting finance, technology and specified energy-sector activities.
Shell’s annual reporting subsequently confirmed that the restrictions had caused it to pause certain Russian liquids-rich shale-exploration activities.
The previous instalments documented those operational consequences.
Yet in June and September 2015, Shell was advancing new commercial arrangements with Gazprom.
Was this necessarily a contradiction in law?
No.
The 2014 sanctions were targeted restrictions.
They did not amount to a blanket prohibition on all business dealings with Gazprom.
They did not automatically prohibit every transaction involving Russian natural gas.
Nor did they establish that the Nord Stream 2 agreement was unlawful.
The US Treasury’s September 2014 announcement shows the particular financial and energy activities being restricted. U.S. Department of the Treasury
Nevertheless, there was an unmistakable political tension.
Western governments were attempting to impose economic costs upon Russia because of its conduct in Ukraine.
At the same time, major Western energy companies were agreeing to pursue infrastructure that could strengthen Russia’s capacity to sell gas directly to European markets.
The companies could argue that they were operating lawfully and addressing legitimate energy needs.
Critics could argue that the proposed infrastructure conflicted with the strategic objectives behind Western policy.
Both positions must be understood.
The documentary record does not support replacing that debate with an unsupported allegation of sanctions evasion.
8. Six days later: Slovakia calls the agreement a betrayal
On 10 September 2015, Slovak prime minister Robert Fico delivered an exceptionally strong response.
Speaking alongside Ukrainian prime minister Arseniy Yatsenyuk, Fico condemned the agreement between Gazprom and its Western European partners.
He described it as a betrayal of Slovakia and Ukraine.
The language was unusually blunt for a disagreement over energy infrastructure.
But the underlying concern was substantial.
Slovakia had historically received Russian gas transported through Ukraine.
Transit arrangements were economically important.
Ukraine also depended upon revenues from transporting Russian gas to European customers.
A major alternative pipeline system could reduce those revenues.
Fico argued that European governments had been discussing ways to support Ukraine while Western companies were simultaneously pursuing a project that could undermine Ukraine’s transit role.
His criticism was therefore not limited to the potential loss of income.
He regarded the arrangement as inconsistent with European political commitments to Ukraine.
The reaction was documented contemporaneously by Associated Press and Reuters-linked reporting.
Yatsenyuk also condemned the project.
He characterised it as damaging to Ukraine’s interests.
At their joint appearance, Yatsenyuk estimated that Ukraine could lose approximately $2 billion annually in transit revenues, while Slovakia could lose approximately $800 million.
Those were political estimates of potential future losses.
They were not established financial consequences of the unbuilt pipeline.
The importance of the statements lies in what they reveal about the contemporary political response.
Only six days after Shell signed the agreement, the governments of two countries directly affected by the proposed route were publicly condemning it. Fox News
9. Ukraine’s objection went beyond transit fees
Ukraine’s concerns were not purely commercial.
For many years, Ukrainian infrastructure had played an important role in transporting Russian gas to Europe.
That role gave Ukraine economic revenue and a degree of strategic importance.
A substantial reduction in transit could weaken both.
From Kyiv’s perspective, Nord Stream 2 threatened to remove part of the economic and political relationship connecting Ukrainian infrastructure with European energy security.
The political circumstances were especially sensitive.
The conflict in eastern Ukraine continued.
Russia’s annexation of Crimea remained internationally contested.
Relations between Moscow and Kyiv were severely damaged.
A new route bypassing Ukraine could therefore have consequences extending beyond pipeline tariffs.
The commercial partners did not necessarily share that interpretation.
Germany and the participating companies could reasonably argue that infrastructure decisions should reflect economics, reliability and future market demand.
But for Ukraine, the project could not be separated from the wider conflict.
This explains why the September agreement attracted a reaction far beyond the energy industry.
It had become a question about the relationship between European commercial interests and European political commitments.
10. Poland joins the opposition
Poland also viewed the proposal with concern.
The September reporting recorded criticism from Polish president Andrzej Duda.
Poland was concerned that new Baltic infrastructure could strengthen Gazprom’s position in the European gas market.
There were also concerns that infrastructure benefiting Germany and Gazprom could be developed without adequate consideration of the interests of other European countries.
The issue was not simply whether Germany wanted additional gas.
It concerned the consequences for the wider European energy system.
The original Nord Stream route already bypassed several countries in central and eastern Europe.
Nord Stream 2 would substantially increase the capacity of that route.
For countries seeking to reduce dependence upon Russian gas, the project appeared to move in the opposite direction.
These concerns would later develop into concrete regulatory action.
At the time of the September agreement, however, they were part of a growing political controversy.
Poland’s government had not yet determined the outcome of the proposed ownership arrangements.
That development lay ahead. Euractiv
11. The European Commission had already defended Ukrainian transit
There is another contemporary record that helps explain the institutional disagreement.
On 21 June 2015, shortly after the preliminary Baltic pipeline agreement, European Commission vice-president Maroš Šefčovič spoke at a security forum in Bratislava.
Šefčovič was responsible for the Energy Union.
He emphasised the strategic importance of continuing Russian gas transit through Ukraine.
He pointed to the capacity of Ukraine’s existing pipeline network.
He also questioned the economic logic of constructing expensive infrastructure primarily to bypass an established transit country.
The remarks were reported by Agence Europe on 23 June.
The Commissioner was not issuing a legal judgment against Shell or the proposed project.
He was articulating an important policy concern.
The European Union’s Energy Union strategy emphasised energy security, integration and diversification.
A project that concentrated additional transport capacity on a route controlled by the same major external supplier raised questions about its consistency with those objectives.
The Commission’s concern therefore predated the September signing.
This is an important historical distinction.
Opposition to bypassing Ukraine did not arise solely because of the September agreement.
It was already part of the European policy debate. Agence Europe
12. October: the European Parliament formally raises the alarm
By October 2015, the controversy had reached the European Parliament.
On 1 October, Parliament issued an official briefing announcing a debate scheduled for 7 October.
The briefing explicitly named Shell alongside Gazprom, E.ON, OMV, BASF/Wintershall and ENGIE.
It stated that Members of the European Parliament were concerned that the project could increase dependence upon Russia.
They also feared that it could weaken Ukraine and adversely affect European countries bypassed by the pipelines.
The briefing identified Estonia, Latvia, Lithuania and Poland among the countries whose political, security and economic interests were under discussion.
This is particularly valuable evidence.
It is not merely a newspaper describing criticism of the project.
It is an authenticated parliamentary publication establishing that Nord Stream 2 had become a formal subject of debate within an EU institution.
The questions went directly to the central issues.
Would the project increase European dependence upon Russian gas?
Would it undermine diversification?
Would it weaken Ukraine?
Would it disadvantage countries excluded from the new route?
These were questions that the September corporate announcement had not resolved.
Primary parliamentary source: European Parliament — MEPs to debate plans to expand Nord Stream, 1 October 2015
Contemporaneous reporting of the debate held on 7 October recorded strong criticism from a number of MEPs.
Some urged the European Union to oppose the development.
Others argued that the project was inconsistent with the Union’s efforts to diversify energy supplies.
The political battle had clearly begun. Agence Europe
13. The fundamental dispute: diversity of routes or diversity of suppliers?
Nord Stream 2 exposed a significant disagreement over energy-security terminology.
For the participating companies, the project offered a new transport route.
That could provide operational advantages.
It might reduce exposure to interruptions involving existing transit arrangements.
It could connect Russian production more directly with large Western European gas markets.
But critics argued that the project did not diversify the underlying gas supplier.
The gas would still originate in Russia.
Gazprom would remain the principal supplier and the controlling corporate participant.
Additional transport capacity could therefore strengthen an existing supplier’s commercial position rather than reduce dependence upon it.
Both arguments had substance.
Multiple routes can improve resilience against a failure affecting one route.
But multiple routes originating from the same supplier do not eliminate the risks associated with dependence upon that supplier.
The September disagreement was therefore not merely semantic.
It concerned two different models of energy security.
One emphasised reliable infrastructure and adequate import capacity.
The other emphasised supplier diversification and reduced strategic dependence.
Shell publicly supported the first argument.
Ukraine, Slovakia, Poland and a number of European parliamentarians emphasised the second.
The documents demonstrate that this disagreement was visible from the project’s earliest formal stages.
14. The shareholders’ agreement did not settle the regulatory position
There is another important distinction between the September announcement and the project’s eventual development.
The agreement was a corporate instrument.
It did not constitute approval from every relevant regulator.
The proposed pipelines would operate across an international maritime environment and connect with European gas infrastructure.
Their development raised questions involving construction permissions, environmental assessment, energy regulation and competition law.
Different legal questions required consideration under different rules.
The fact that Gazprom and its Western partners signed a shareholders’ agreement did not determine how every provision of European energy law would apply.
Nor did it remove the possibility of objections from national competition authorities.
That became highly significant when the proposed ownership structure was examined.
It is important not to apply later legislation retrospectively.
The legal framework governing pipelines to and from third countries was subsequently amended.
Those later developments cannot simply be treated as if the same provisions already governed the September 2015 agreement.
The correct historical approach is to examine the law as it stood at the time, then trace subsequent changes.
15. What the subsequent court record establishes
A later judgment provides authoritative confirmation of the distinction between the original corporate proposal and the project’s subsequent legal structure.
On 12 July 2022, the Court of Justice of the European Union delivered its judgment in:
Nord Stream 2 AG v European Parliament and Council of the European Union, Case C-348/20 P.
The case concerned amendments to EU natural-gas market legislation introduced in 2019.
Those amendments extended certain rules governing the internal gas market to pipelines connecting EU member states with third countries.
The proceedings concerned the admissibility of Nord Stream 2 AG’s challenge to the legislation.
The Court held that the company’s action was partially admissible and referred the relevant issues back to the General Court.
It did not make a finding that Shell’s 2015 agreement was unlawful.
Nor did it determine that Shell had violated sanctions.
The judgment is nevertheless important for the documentary history.
Its account of the project’s later corporate structure identifies Gazprom as the sole shareholder of Nord Stream 2 AG.
It also records financing arrangements involving five Western companies, including Royal Dutch Shell.
The contrast with the September 2015 announcement is significant.
In September 2015, Shell was publicly identified as an intended 10 per cent shareholder.
Under the later arrangements described by the Court, Shell was a financing participant, not a shareholder in the project company.
The development between those two positions belongs to the next stage of the story.
The judicial record confirms that the original ownership plan did not become the permanent structure of the project. Italaw
16. The importance of Shell’s participation
Shell was not a peripheral participant in the September agreement.
Its chief executive was one of the signatories.
The company’s public statement endorsed the commercial justification for the project.
The proposed ownership structure allocated Shell a significant minority interest.
And the agreement was part of a broader relationship with Gazprom that extended from Sakhalin LNG production to European gas infrastructure.
The connection with earlier events is particularly important.
In 2006–07, Shell had surrendered majority control of Sakhalin II following the confrontation surrounding the project’s development.
Gazprom became the controlling shareholder.
Shell nevertheless remained involved.
By 2014, the companies were discussing LNG expansion.
In June 2015, they entered a wider strategic cooperation agreement.
And in September 2015, Shell joined Gazprom and other European companies in proposing one of Europe’s largest new gas pipeline projects.
The relationship had therefore evolved far beyond the original Sakhalin investment.
Shell was no longer simply preserving an existing Russian asset.
It was actively exploring further commercial integration with Gazprom.
The September documents establish that much.
They do not establish that Shell supported Russian government actions in Ukraine.
Nor do they show that participation in the project constituted a sanctions violation.
Those claims would require evidence not present in the records examined here.
The significance of the agreement lies in the extent of the proposed cooperation and the political environment in which it was pursued.
Documentary Findings
Established by authenticated corporate records
On 4 September 2015, Ben van Beurden signed the Nord Stream 2 shareholders’ agreement at the Eastern Economic Forum in Vladivostok.
The signatories represented Gazprom, BASF, E.ON, ENGIE, OMV and Royal Dutch Shell.
The proposed project involved two additional offshore pipelines across the Baltic Sea.
Their combined annual capacity would be approximately 55 billion cubic metres.
Gazprom’s announced ownership share was 51 per cent.
Shell’s proposed interest was 10 per cent.
The agreement identified New European Pipeline AG as the intended project vehicle.
Van Beurden publicly justified the project by reference to Europe’s future gas requirements and declining domestic production.
These facts are confirmed by the 4 September Gazprom and OMV announcements. Gazprom
Established by contemporaneous reporting
Reuters reported the June and September agreements as developments in Gazprom’s effort to expand direct gas-export infrastructure to Europe.
The proposed route would bypass Ukraine.
On 10 September, Slovak prime minister Robert Fico publicly condemned the agreement as a betrayal.
Ukrainian prime minister Arseniy Yatsenyuk also opposed it.
Both leaders warned of substantial potential losses of transit revenue.
Those losses were forecasts attributed to the political leaders, not independently established consequences.
Polish political leaders also expressed opposition to the project. La Tribune
Established by European institutional records
On 1 October 2015, the European Parliament announced a debate concerning Nord Stream 2.
Its briefing explicitly identified Shell and the other participating companies.
It recorded concerns about dependence upon Russian gas, Ukraine’s strategic position and the interests of European countries bypassed by the proposed route.
The debate was scheduled for 7 October.
Contemporaneous reporting confirms that the project attracted substantial criticism from MEPs.
These records establish political opposition.
They do not establish a judicial ruling that the September agreement was illegal. European Parliament
Established by subsequent judicial proceedings
The Court of Justice’s judgment of 12 July 2022 confirms that Nord Stream 2 AG subsequently operated under a structure in which Gazprom was the sole shareholder and Western companies, including Shell, were involved in financing.
The judgment concerned later EU gas-market legislation.
It does not establish wrongdoing by Shell.
It is relevant here because it prevents the proposed 2015 shareholding arrangements from being mistakenly presented as the project’s final ownership structure. Italaw
Not established
The documents do not establish that Shell breached sanctions by signing the September 2015 agreement.
They do not establish that Shell endorsed Russia’s actions in Ukraine.
They do not establish that Shell had completed the acquisition of its proposed 10 per cent shareholding.
They do not establish that construction had received every required approval.
They do not establish that the proposed pipelines would automatically replace all Ukrainian gas transit.
They do not establish that the project was economically unnecessary.
They do not establish that it was economically indispensable.
And they do not establish that the September agreement settled the project’s eventual ownership, financing or regulatory position.
Commentary: A Commercial Decision With Political Consequences
The September 2015 agreement illustrates a recurring difficulty in the relationship between multinational energy companies and governments.
Infrastructure investments are often presented in commercial terms.
And frequently, those commercial arguments are substantial.
Europe needed natural gas.
Domestic production was declining.
New infrastructure could offer additional import capacity.
Shell and the other companies participating in the agreement were pursuing opportunities within their established areas of expertise.
There was nothing inherently surprising about major energy companies considering another large gas pipeline.
But Nord Stream 2 was not being proposed in an ordinary political environment.
Russia had annexed Crimea.
The conflict in eastern Ukraine continued.
Western governments had introduced economic sanctions.
The European Union was attempting to strengthen energy security and maintain support for Ukraine.
Within that environment, Shell and other Western companies agreed to pursue infrastructure that could reduce Ukraine’s role in Europe’s gas supply system.
For Gazprom, the attraction was obvious.
A direct Baltic Sea route could reduce reliance upon existing transit countries.
It could also strengthen Gazprom’s relationships with major Western European energy businesses.
For Shell, the attraction was different.
Participation offered a prospective stake in important gas infrastructure and an opportunity to deepen an already substantial commercial relationship with Gazprom.
The company’s public argument focused upon European energy demand.
But commercial logic did not remove the political implications.
A project can be economically attractive to its investors while creating serious disadvantages for countries outside the investment agreement.
That was precisely the concern expressed by Ukraine and Slovakia.
Their objections were not evidence that Shell had broken the law.
They were evidence that the commercial consequences of the project extended beyond its immediate shareholders.
There is a broader point about corporate responsibility.
Energy companies are entitled to pursue lawful commercial opportunities.
But large energy infrastructure can influence national security, international relations and the economic resilience of entire countries.
Those consequences deserve consideration alongside projected financial returns.
The September announcement demonstrated that Shell considered additional Russian gas infrastructure commercially desirable.
The reaction from Ukraine, Slovakia and the European Parliament demonstrated that important political institutions saw the project differently.
That divergence deserves to be preserved in the historical record.
The lesson of Sakhalin
There is also a revealing continuity with the earlier Sakhalin story.
Shell had experienced the consequences of Russian political and regulatory power during the Sakhalin II confrontation.
The company’s original majority position had been substantially reduced.
Gazprom had taken control.
Yet Shell remained commercially committed to the relationship.
By 2015, the companies were discussing expansion in Sakhalin and infrastructure in Europe.
The partnership had survived a major dispute over the ownership and development of Sakhalin II.
It was now surviving serious geopolitical tension.
But the Nord Stream 2 agreement would encounter obstacles of its own.
This time, the pressure would not arise primarily from Russian environmental regulators or negotiations over production-sharing arrangements.
It would emerge from European institutions and competition authorities.
The proposed ownership structure, confidently announced in September 2015, would prove particularly vulnerable.
That later development provides an important reminder about the difference between corporate ambition and completed investment.
The September agreement was real.
The signatures were real.
Shell’s participation was real.
But the proposed ownership arrangements were not immutable.
And the political controversy had only begun.
Principal Documentary Sources
1. Gazprom — 4 September 2015
Gazprom, BASF, E.ON, ENGIE, OMV and Shell sign Shareholders Agreement on Nord Stream 2 project.
The central primary document confirming the Vladivostok signing, participants, proposed shareholdings, pipeline capacity and executive statements.
Read Gazprom’s official announcement
2. OMV — 4 September 2015
Gazprom, BASF, E.ON, ENGIE, OMV and Shell sign Shareholders’ Agreement on the Nord Stream 2 project.
Independent company-authored confirmation of the terms and Shell’s participation, including van Beurden’s statement.
Read OMV’s official announcement
3. Reuters — 18 June 2015
Contemporaneous reporting of the preliminary Baltic gas-transmission agreement involving Gazprom, Shell, E.ON and OMV.
Reuters report: Gazprom announces agreement with Shell, E.ON and OMV
4. Reuters — 4 September 2015
Contemporaneous account of the shareholders’ agreement, estimated project cost and anticipated construction timetable.
Reuters: Gazprom and European partners sign Nord Stream 2 agreement
5. Associated Press — 10 September 2015
Reporting of the objections raised by Slovak prime minister Robert Fico and Ukrainian prime minister Arseniy Yatsenyuk, including their estimates of potential transit-revenue losses.
Associated Press: Ukraine and Slovakia condemn Nord Stream 2
6. Agence Europe — 23 June 2015
Contemporaneous reporting of European Commission vice-president Maroš Šefčovič’s position on the strategic importance of continuing gas transit through Ukraine.
Šefčovič calls for continued gas transit through Ukraine
7. European Parliament — 1 October 2015
MEPs to debate plans to expand Nord Stream pipeline from Russia.
Official parliamentary briefing identifying Shell and other participating companies and setting out concerns about energy dependence, Ukraine and bypassed EU countries.
Read the European Parliament briefing
8. Agence Europe — 9 October 2015
Contemporaneous reporting of the 7 October European Parliament debate and opposition to the project.
European Parliament debate: Opposition to Nord Stream 2
9. US Department of the Treasury — 12 September 2014
Official announcement of the expanded Russian financial and energy-sector sanctions in force before the September 2015 agreement.
US Treasury: Expanded sanctions against Russia
10. Court of Justice of the European Union — 12 July 2022
Nord Stream 2 AG v European Parliament and Council, Case C-348/20 P.
Subsequent judicial record concerning EU gas-market regulation and the project’s later corporate and financing structure.
Read the Court of Justice judgment
11. OSW Centre for Eastern Studies — 26 April 2017
The Nord Stream 2 financing agreements.
Independent analysis documenting the eventual financing structure and explaining how the original shareholding arrangements failed following Polish competition objections.
Archive disclaimer: This instalment distinguishes authenticated corporate documents, contemporary political statements, independent journalism, parliamentary records, subsequent judicial material and editorial interpretation.
The 4 September 2015 shareholders’ agreement is evidence of the participating companies’ stated intentions and contractual arrangements at that date. It must not be treated as proof that all proposed equity acquisitions were ultimately completed.
The Court of Justice proceedings cited concern subsequent EU gas-market legislation, not a prosecution of Shell or an adjudication of its conduct in September 2015.
No sanctions violation, unlawful transaction or other misconduct by Shell is alleged or established in the documents examined.
Site-wide disclaimer also applies.
NEXT: The Ownership Plan Unravels — Poland Challenges Gazprom and Shell’s Nord Stream 2 Joint Venture
The September 2015 agreement proposed that Gazprom would hold 51 per cent of Nord Stream 2, with Shell and four other Western companies holding the remaining shares.
But the plan encountered an obstacle that the signing ceremony in Vladivostok had not resolved.
Competition law.
In December 2015, the participating companies sought approval from Poland’s competition authority for their proposed joint venture.
The application would eventually be examined by Poland’s Office of Competition and Consumer Protection, known as UOKiK.
In July 2016, the authority published objections.
It was concerned that the proposed concentration could strengthen Gazprom’s already substantial position in the Polish gas market.
The applicants subsequently withdrew their notification.
The original multinational ownership structure could not proceed as planned.
Shell remained interested in the project, but its participation would eventually take a different form.
A subsequent financing agreement would leave Gazprom as the project company’s sole shareholder, with the Western companies providing substantial funding.
The documentary trail is unusually clear.
The proposed shareholding structure can be found in the September 2015 corporate announcements.
The Polish competition authority’s objections were publicly reported in July 2016.
And the later financing arrangements were documented in 2017. PAP
The next Shell Leaks File — SLF-2007-086 — will examine how Poland’s competition authority challenged the original Nord Stream 2 ownership structure, why Gazprom’s Western partners withdrew their proposed share acquisitions, and how Shell’s involvement survived the failure of the initial plan.
It will also examine an important distinction for shareholders.
A company can cease to be a proposed equity partner in a controversial project without necessarily ceasing to provide the money required to build it.
The evidence establishing how that distinction applied to Shell lies in the corporate, regulatory and financial records that followed the Vladivostok agreement.
*This website and sisters royaldutchshellgroup.com, shellnazihistory.com, royaldutchshell.website, johndonovan.website, shellnews.net, and shellwikipedia.com, are owned by John Donovan - more information here. There is also a Wikipedia segment, the Shell DPA Files, "Shell and the Spies", the Shell Leaks files, as well as books written and published by John Donovan - Kindle eBooks. Timeline of the Donovan Shell Feud. Toxic History of Royal Dutch Shell Group. Shell and the Donovans: The Full Media Record — 550+ Articles, 110 Books, 40 Years. *All created and supported by internet wizz, Nick Gill.
