The receipts chapter. Every finding, every OFI, every deliverable — laid out with document references and traceable to the live management system. This is the page the close-out visit was built around.
Shell's draft report landed on 5 February 2026. The first Change Management Plan went back the next day. What followed was not a patch job — it was a full rebuild of the Seagull management system with ISO 45001 as the backbone and Shell's findings as the delivery roadmap. Nine weeks later, the numbers tell their own story.
Each block below takes one finding or OFI, restates what Shell asked for in a single line, and lists the deliverables that answered it — with document references you can cross-check against the Document Register in Chapter 07. Where relevant, the finding's entry on the NCR register is also listed for traceability.
For each finding: what Shell asked for, what we built, and where the evidence lives. Document references follow the integrated management system's SM/[System]/[Type]/[Seq] format.
Shell asked for: written confirmation from a competent Maltese government body specifying the company's exemption status from S.L. 480.05 and the Arms Act.
External · In escalationThe one finding that sits outside Seagull's direct control. The Malta authority is the single point of dependency. Every other action within Seagull's control has been taken and the escalation remains live.
Shell asked for: a unified organisation-wide risk management framework covering WAF and IOR, integrating HSSE, documented in SOPs, ISO 45001-aligned.
Closed · Evidence completeSM/HSE/PRO/001 Hazard ID & Risk Assessment ProcedureSM/SEC/PRO/001 Security & Business Risk Assessment ProcedureSM/HSE/RA/002–010 Nine H&S Risk Assessments (144 hazards)SM/CAM/BRAG/001–009 Nine Basic Risk Assessment GuidesSM/INT/DOC/003 Risk Screening Tool — interactive gatewayThis was the rebuild. Nine H&S risk assessments, nine BRAGs, two risk procedures, the Risk Screening Tool, and ISO 45001 as the backbone of the management system — all delivered inside nine weeks. The framework is live across every operational theatre and every Seagull entity.
Shell asked for: a formal media and social media policy covering office and operational staff, communicated company-wide and reinforced through training.
Closed · Evidence completeSM/INT/POL/008 Social Media Policy v1.0C16 — Social Media Policy Awareness (live)SM/INT/FORM/002 New Starter ChecklistClosed with both the policy document and the delivery mechanism — the policy itself plus an LMS course assigned as mandatory training across office and operational staff.
Shell asked for: all personal insurance documentation updated to reflect the correct legal entity (Seagull Malta) and communicated accordingly.
Closed · Evidence completeFirst finding closed. Straight administrative correction, evidenced and lodged within two weeks of the draft report landing.
Shell asked for: a formalised and validated MOU with the Nigerian Navy authorising maritime security operations in Nigerian waters.
Closed · Evidence completeThe MOU underpins Seagull's legitimacy for armed operations in Nigerian waters. Closed with the document itself, the training review, and the operational readout into WAF ops.
Shell asked for: VPSHR explicitly incorporated into procedures, training materials and use-of-force guidelines, with awareness sessions across office and deployed personnel.
Closed · Evidence completeSM/OPS/PRO/001 Rules on the Use of Force — VPSHR inserted (Section 4 + abbreviations)SM/OPS/SOP/001 IOR SOP and Annexes A–H — VPSHR referencedSM/TRG/DOC/001 Human Rights PCASP Training (28 slides, UDHR / VPSHR / ICoCA)SM/TRG/DOC/002 Human Rights Staff & Management Training (28 slides)SM/INT/POL/002 Code of Conduct — VPSHR & ICoCA alignedSM/CAM/BUL/001 awareness bulletin deployed via campaign portalVPSHR is now woven through the policy library, the RUF, the SOPs, the training platform and the campaign. Not a reference — an integration.
Shell asked for: a full IRT exercise with realistic operational scenario, documented with objectives, lessons learned and corrective actions, integrated back into the Incident Response Plan.
Closed · Evidence completeSM/HSE/RPT/001 IRT Exercise Report — Office FireSM/INT/PRO/006 Incident & Crisis Management Plan — cross-referencedSM/INT/PRO/016 Emergency Preparedness & Response Procedure07 · Audit and Review / Exercises and Drills establishedA tabletop exercise with genuine friction, honestly reported. The mistakes in the report are real mistakes, because a polished exercise wouldn't have earned the OFIs that came out of it. Those OFIs are now tracked separately and working toward closure ahead of 3 May.
Compact format for the lighter-touch items — one row per OFI with the deliverable and document reference.
Formal Management of Change process
SM/INT/PRO/013 procedure,
SM/INT/FORM/003 Word form, SM/INT/REG/009
register, online Change Request form at
campaign/tools/change-request.html
Structured annual Management Review cycle
SM/INT/PRO/019 Management Review Procedure built S34.
SM/INT/MRM-001 v1.1 first formal MR minutes —
ISO 45001 scope setting
Sanctions listings in compliance workflows
SM/INT/REG/007 External Standards register updated.
Code of Conduct, Risk Screening Tool, Sanctions Screener all aligned
Vessel delay wording — safety reasons
SM/OPS/SOP/001 IOR SOP — Annex A & H amended 26 Jan to
clarify legitimate safety-led delays (weather during transfer,
operational risk)
UKMTO as primary vessel defence contact
SM/OPS/SOP/001 annexes updated — UKMTO designated as primary
incident reporting pathway. Cross-referenced in training course
C09 Incident Reporting
Minimum standards for Security Escort Vessels
SM/OPS/SOP/002 WAF SEV Operations SOP + Annex A (MSLO).
SM/SEC/FORM/003 SEV Vessel Information Form (39 vessel doc
items). SM/SEC/PRO/004 and 005 SEV approval
procedures refreshed
Drugs & Alcohol policy applicability
SM/INT/POL/010 Drugs & Alcohol Policy v1.0 and
SM/INT/PRO/021 D&A Testing Procedure — applicability
clarified across PCASP, office and WAF operational staff
Formal PCASP security briefing to Master
IOR/Briefings/For Distribution
Andy, Dennis and Neil reconnect with Seagull on 3 May. Every finding walked through against its evidence. Every OFI cross-referenced to its document. The Combined Work Programme open on screen, the Document Register searchable, the LMS live, the HSE app reporting, and Libero's ISO 45001 Stage 2 result (21 April) already on the table. The audit closed formally on 19 February — that was the day the starting whistle blew. This is the day we show what was done with the months that followed.