Two days in Piraeus, 20 – 21 January 2026. The paperwork closed. The conversation
opened. This is where Shell's Maritime Security team walked the system in person
and where the real picture came into focus — for both sides.
By the time the audit team arrived in Piraeus, the 205-file DD pack had been on
Shell's servers for nearly two weeks. The paper-based part of the assessment was
essentially complete. What came next was something different — the
in-person audit: the conversation, the walk-through, and the moment the
management system has to live in the room with the people who built it.
Shell brought three. Andy Keane leading as Manager Maritime Security, Dennis Kerlin
covering Strategy & Risk, and Neil Murray as the West Africa Assessor. Two full
days on the ground. Day 1 opened on the integrated management system and Indian
Ocean Region operations. Day 2 pivoted to West Africa, SEV operations and the
SR Platforms / Nigerian Navy relationship.
What follows is a factual record of the two days — who came, what was walked, the
initial observations Shell shared verbally before leaving, and the list of documents
they asked us to provide in the days that followed.
Audit Lead
Andy Keane
Manager, Maritime Security Shell International T&S
Leads the Shell Maritime Security function within Trading & Supply. Chaired
both days of the audit and signed off the final DD report acceptance on
19 February.
Strategy & Risk
Dennis Kerlin
MS Strategy & Risk Lead Shell International T&S
The day-to-day lead on the Seagull engagement from early December onwards.
Ran the pre-audit scheduling, drove the document requests, and has been the
principal point of contact through close-out.
WAF Assessor
Neil Murray
MS Assessor — West Africa Shell International T&S
Shell's West Africa specialist. Led the Day 2 conversation on SEV operations,
vessel hardening, host nation force engagement and the SR Platforms / Nigerian
Navy arrangements.
Day One
20 January 2026 · Piraeus
Management system & Indian Ocean operations
Opened with introductions, scope confirmation and a walk-through of the Shell
PMSC audit process. From there into the integrated management system as it
stood: ISO certification posture, corporate governance, procedures and
policies, and the IOR operational pack.
Day two pivoted westwards. Neil Murray led the conversation on the WAF picture:
SR Platforms, the Nigerian Navy MOU, Mediator II as the worked vessel example,
and the end-to-end SEV inspection and assurance process. The day closed with
initial verbal observations and the document request list.
Host Nation Force MOU — Nigerian Navy
SR Platforms relationship & operating permits
MV Mediator II — specs, surveys, condition
Vessel hardening & ballistics certification
SEV inspection checklists & action items
Crewing, training matrices, HSE KPIs
Contractor management system
Close-out conversation & initial observations
Initial feedback · verbal close-out
What Shell saw as strengths
Six positive observations delivered verbally on Day 2 and captured in the formal
audit comments. Recorded here exactly as worded by the audit team.
Good clear boundaries between Commercial and Operational roles
Ongoing focus on improving Management Systems and SOPs
Clear, concise SOPs
Experienced shore-based personnel driving company improvements — open and transparent
Availability of digital and intelligence support from Vanguard
Critical spares requirements and checks for SEVs
Initial feedback · to confirm prior to Stage 1 DD
Areas flagged for improvement
Seven items raised as things to confirm or develop before Shell could sign off
Stage 1 due diligence. These became the backbone of the Change Management Plan
submitted on 6 February.
Provide clarity around the exemption from Maltese PMSC law with a document from the Malta government
Develop the risk management process — from Risk Identification through Risk Control and Mitigations — for all Seagull operations (WAF / IOR)
Provide a Media Policy (including Social Media) for Seagull employees — office and operational
Personal insurance — company on policy referenced Seagull UK rather than Malta
Nigerian Navy MOU — clarity on arrangements and scope
Reference VPSHR and adopt its recommendations into procedures and practices
Complete and document an IRT exercise
Additional value-add observations
Further recommendations from the audit team
Nine further observations offered as improvements that would add value to the
system — not blockers, but the kind of feedback that only comes from auditors
who have already decided the relationship is worth investing in.
Document and implement a management of change process so that procedure updates are reviewed and rolled out with accountability
Annual Management Review — ensure clear accountability for actions and regular follow-up
Check sanctions listings for compliance
Review wording about delaying vessels to ensure it's clear a client vessel can be delayed for safety reasons (e.g. bad weather for transfer)
Vessel defence section — ensure primary response to incident is UKMTO
Seagull minimum standards for SEVs
Clarify Drugs & Alcohol policy applicability
Implement PCASP security briefing to Master
Signalled possible return in one year for a surveillance visit as documentation and changes continue
Post-audit document request
Ten items on the list
Requested 21 Jan · delivered 5 Feb
Details of legal arrangements between Seagull Malta and Seagull Nigeria
SEV incident reports / investigations
SEV inspection records (including surprise inspections)
SEV provider supplier audit
VRA for 2 × IOR transits and 2 × SEV
D&A test records for PCASP
D&A testing of SEV crew verification
Record of lost weapons
2 × post-transit reports (PCASP)
Admin procedure for PCASP (use of online tool)
26 January 2026 · Five days later
A short note from Dennis, thanking the team for their hospitality and openness
during the two days. No fanfare, no corporate script — just the signal that the
audit had been a genuine working conversation and that the relationship was
going to run on that basis from here on in.
