Where we were on 7 January 2026. A portrait, in good faith, of the management
system Shell's auditors were handed on day one — the honest starting line for
everything that has followed.
The PMSC Vetting Questionnaire landed on 16 December 2025 with a 7 January
deadline. Three working weeks, spanning Christmas and New Year. The pack that came
out the other side of that window was 205 files across three sections —
Company & Management System, Operations, and West Africa — and it represented
Seagull Maritime exactly as it stood on that date. No more, no less.
Everyone who could contribute, did. The structure, the sections, the evidence pool —
pulled together across the holiday period against a fixed deadline, in parallel with
client taskings that didn't pause. The pack went in on time and reflected the
management system honestly as it stood on 7 January.
What follows is a factual account of what that pack contained. It isn't a confession
and it isn't dressed up. It's the baseline — and the reason every chapter that comes
after this one has something to measure against.
205
Files submitted across three sections
3 wks
Build window across Christmas
1
Person building the whole pack
7
Policies in the library
5
Management-system procedures
4
Operational SOPs
1
Rules on the Use of Force doc
0
Risk assessments in the pack
Section A · The largest folder
Company & Management System
The company shop window. Structure, ownership, UBO, legal statements, incorporation
docs, ISO certificates (18788, 28000, 28007, 9001), insurance, and the
management-system evidence Shell would use to form a first impression. Ten numbered
sub-folders, each exactly as complete as the underlying system allowed.
Company structure, UBO, governance and legal statements
7 policies — Code of Conduct, Human Rights, Anti-Bribery, Grievance, Equal Opps, Data Protection, ABC
4 ISO certificates — no 45001
H&S evidence: one statistics sheet, one policy manual
Recruitment & training — MSO syllabus, one monitoring screenshot, one master evaluation
Emergency response — Business Continuity and Incident & Crisis plans (SMS-PRO branded)
Section B · Operations
How we actually run taskings
The operational heart of the pack — SOPs, RUF, weapons management, employment
screening, flag & port state approvals, VBAs. The intent was to show Shell what
a Seagull deployment looked like from embarkation to disembarkation.
A single Rules on the Use of Force PDF — no form annexes
SOP-3003 Weapons & Security Equipment plus two ERP screenshots
3 example VBAs (Golden Palm, Grey Palm, Kapitan Konig)
Flag & Port State approvals — duplicated from Section A because there weren't enough files to fill two folders
One Post Transit Report form — the whole "operational forms" pool
Weapons end-user certs (Djibouti) and UK export licences
Section C · West Africa
Nigeria, Mediator II, and the SR Platforms relationship
Section C was the WAF chapter of the pack — the Host Nation Force MOU,
MV Mediator II as the worked example, vessel hardening, crew training,
SEV inspection checklists, and SR Platforms' operating documents. It was the
section that would later drive most of the Day 2 audit conversation.
Seagull – Nigerian Navy MOU (July 2025)
MV Mediator II — 15 vessel documents, specs, surveys, certificates
SR Platforms SMM, NPA licence, NSCDC permit, NIWA permit
SEV inspection checklists (April 2025, Mediator II) — example and action items
Vessel hardening — ballistics certificate for Mediator II
Crew training matrix, drill matrix, HSE KPI and monthly HSSE reports
This was the baseline. Everything that follows is measured against it.
7 policies became 17. 5 procedures became 20-plus. 4 SOPs became a proper IOR
operational pack with RUF, annexes and twelve forms. Zero risk assessments became
nine with 144 hazards and nine plain-language guides. The gaps the audit found
weren't minor — and that's exactly why the response had to be the whole system,
not a patch job. Chapter 03 is where Shell's team walked into the room and saw
this pack for themselves.
