THE SHELL LEAKS FILES: 25 SEPTEMBER 2026
SLF-2007-068
The Sakhalin Papers LVIII: The Audit After the Spill — What Shell’s Lenders Were Being Told About Sakhalin II
In December 2005, an independent lenders’ audit of Sakhalin II Phase I entered the documentary record. A later German parliamentary motion, citing the report by name, said that two-thirds of 90 matters examined produced negative results concerning compliance with environmental standards. A separate submission by WWF, Friends of the Earth and The Corner House said the same audit criticised management of oil-spill response equipment and found that materials used after the Cristoforo Colombo accident had not been replaced. The audit itself has not been located in the publicly accessible sources reviewed for this file. Those descriptions must therefore remain attributed. But Shell’s own 2005 Sustainability Report independently acknowledges another serious compliance problem: contractors had not always followed the agreed safeguards for environmentally sensitive river crossings, forcing Sakhalin Energy to halt its winter work programme, retrain contractors and tighten monitoring.
Archive reference: SLF-2007-068
Collection: The Sakhalin Papers
Principal audit cited in the record: 2005 Lenders Tier III HSE Audit for Phase One, RSK ENSR, December 2005
Authenticated corporate source: The Shell Sustainability Report 2005
Lender records: European Bank for Reconstruction and Development Phase I project record and 2005 Annual Report
Contemporaneous reporting: The Observer, June 2005; Financial Times, December 2005
Parliamentary records: German Bundestag Drucksache 16/1668; UK House of Commons Environmental Audit Committee evidence
Judicial record: Export Credits Guarantee Department v Friends of the Earth [2008] EWHC 638 (Admin)
Evidence standard: The underlying RSK ENSR audit has not been located in the publicly available record examined here. Statements about its findings are therefore attributed to the organisations and parliamentarians who cited it. Shell and lender statements are identified as such. No court ruled on the findings of the December 2005 audit.



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.






THE SHELL LEAKS FILES: 15 SEPTEMBER 2026

























