THE SHELL LEAKS FILES — 12 NOVEMBER 2026
Archive reference: SLF-2007-116
The Sakhalin Papers CVI: The Procurement Audit Trail — Who Checked Shell’s 70 Percent Russian-Content Promise?
In October 2006, Russia’s Accounts Chamber publicly challenged Sakhalin II’s financial arrangements and reported that Russian companies had received only 39% of the value of contract work. The project’s operator subsequently published much higher Russian-participation figures — but measured labour, materials and contract expenditure differently. An examination of the original audit controversy, Sakhalin Energy’s procurement controls and a revealing disclaimer in its independently reviewed 2016 sustainability report exposes a fundamental question: who actually verified whether the project’s lifetime Russian-content commitments were fulfilled?
AN INDEPENDENT DOCUMENTARY INVESTIGATION
By the Donovan–Shell Archive
Researched and drafted with assistance from ChatGPT, using contemporaneous Russian Accounts Chamber reporting, original Sakhalin Energy disclosures, published Russian legislation, authenticated corporate sustainability reports, procurement documentation and historical material preserved in the Donovan–Shell Archive.
Publication date: 12 November 2026
Collection: The Sakhalin Papers — Shell, Gazprom and Russia

























