Phase 01
Pre-engagement
How it started — a warm introduction and a first look under the bonnet.
16 October 2025
First contact — Teams call with Shell
Richard Podmore made the introduction and the first Teams call landed on the calendar.
A chance to put faces to names and — on our side — to understand what Shell would expect
of a partner sitting this close to their supply chain.
17 – 20 October 2025
Early data exchange with Andrew Aitchison
Andrew opened the door on Shell's side. Company information, structure, certifications —
the quiet administrative groundwork that always precedes the real conversation.
Phase 02
Formal engagement
Vetting becomes real. A clock starts.
2 December 2025
Nigerian Navy MOU triggers full vetting
The MOU conversation tipped us from "interesting partner" into "needs proper due diligence".
Shell's process engaged formally from here.
11 – 12 December 2025
Dennis Kerlin takes the reins
Dennis came in as the Shell MS lead on the engagement. From this point, everything
routed through him — and, even at his busiest, he kept the line open.
16 December 2025
Intro call · PMSC Vetting Questionnaire issued
A proper introduction call on both sides, followed by Shell's PMSC Vetting Questionnaire
landing in the inbox with a 7 January deadline. Three working weeks including
Christmas. The team knew exactly what that meant.
17 December 2025
Shell upload folder provisioned
Secure transfer channel opened on Shell's side. From here, every document we sent
Shell's way had a traceable home.
Phase 03
DD Pack & scheduling
Christmas cancelled. Pack built. Dates locked.
22 December 2025
Team mobilisation
Internal all-hands email — this one mattered, so the holiday was going to be short.
Everyone who could contribute, did.
7 January 2026 · Milestone
Due Diligence submission delivered — on time
Full DD pack submitted against Shell's PMSC Vetting Questionnaire on the deadline.
It represented the management system as it stood on that date — the version of
Seagull that Shell would be auditing three weeks later. The honest starting line.
12 January 2026
Audit team confirmed
Shell confirmed the on-site team: Andy Keane leading, Dennis Kerlin
and Neil Murray alongside. Dates locked for the following week in Piraeus.
16 January 2026
Pre-audit call — Malta, Djibouti, last asks
A working call to clear the final scope items: Malta licence position, Djibouti
end-user certificate status, a few last document requests. The kind of call where
both sides know the audit is real now.
Phase 04
On-site audit
Two days in Piraeus. The system meets the people.
20 January 2026 · Day 1 · Milestone
Piraeus — the system walked in practice
Day one opened with Andy, Dennis and Neil in the room and the Seagull team across
the table. IOR ops, document control, training records, risk — the walk-through of
a management system being audited as it's actually lived, not as it's written down.
21 January 2026 · Day 2 · Milestone
West Africa focus · close-out conversation
Day two pivoted onto WAF — SEV operations, supplier DD, Nigerian context — and
closed with the team's early observations. Candid, fair, and the first honest view
of where the gaps were.
26 January 2026
Thank-you note from Dennis
A short, human email from Dennis thanking the team for their hospitality and openness
during the audit. Small gesture, but it said a lot about how the relationship was
going to run from here on in.
Phase 05
Interim & first responses
The draft lands. The work begins.
29 January 2026
Compiling additional evidence
Post-audit document requests worked through methodically. Nothing dramatic — just
the steady rhythm of closing open items one at a time.
5 February 2026 · Milestone
Additional documents delivered · Draft Audit Report received
The last batch of post-audit documents went out, and Shell's Draft Audit Report came
back the same week. Seven findings, a set of opportunities for improvement, and a
clear picture of what close-out was going to look like.
6 February 2026
First Change Management Plan submitted
Less than 24 hours after the draft landed, the first CMP went back to Shell —
a statement of intent as much as a plan. Every finding owned, every action dated.
13 February 2026
CMP follow-up
Updated version circulated, building out the detail on each action and closing the
loop on initial OFI responses.
16 February 2026
CMP with OFI responses
Full OFI responses incorporated — the first version of the plan that felt genuinely
complete. Shared with Dennis and the team for comment.
19 – 20 February 2026 · Milestone
Final DD Report accepted
Andy Keane confirmed the final report. A quiet email, a big moment —
the audit was formally closed on Shell's side and the ball was entirely in ours
to deliver against.
26 February 2026
Plan progress confirmed
Dennis came back with confirmation that Shell were comfortable with the
direction of travel. Room to get on with the work without looking over a shoulder.
Phase 06
Execution
Heads down. Nine weeks of real build — with one significant disruption along the way.
February 2026 · Milestone
Management Review — ISO 45001 in mind, setting the tone
Formal Management Review held on the back of the accepted final report, with the
Shell findings, the OFIs and the ISO 45001 gap analysis all on the table at the
same time. This was the moment the programme was shaped: 45001 as the backbone,
Shell overlaid, integrated management system as the delivery vehicle. Every
execution-phase decision that follows in this timeline traces back to the minutes
of that review.
February 2026
Foundation work begins
Straight out of the Management Review — ISO 45001 policy suite, Context of the
Organisation, Interested Parties, scope statements, and the backbone of the
integrated management system. Quiet, unglamorous, structural work that had
to come before anything else.
Early March 2026
Risk framework rebuilt from the ground up
Nine H&S risk assessments (144 hazards), nine plain-language Basic Risk Assessment
Guides, a new Security & Business RA procedure, and the Risk Screening Tool wired
into the campaign portal. Risk became the spine of the system, not a bolt-on.
Mid-March 2026
Iran – US conflict · focus pulled to operations
The Persian Gulf situation escalated and, overnight, the compliance programme took a
back seat. Operational support, client briefings, vessel movement advice, daily threat
assessments for the region — the real job came first. Close-out work paused where it
had to and the team ran both lanes in parallel for nearly two weeks before the
programme caught its breath again.
Late March 2026
IRT tabletop exercise · first live drill evidence
First Incident Response Team tabletop exercise run and formally reported — seven
participants, an office-fire scenario in Piraeus, and deliberately unpolished so the
report reflected a real exercise, not a rehearsal. Four OFIs captured and logged on
the NCR register the same day.
March – April 2026
SOPs, RUF and the IOR pack
IOR Standard Operating Procedures, Rules on the Use of Force, annexes, and a full
suite of operational forms. The on-deck experience Shell walked through in January,
now in writing — and cleaner.
Early April 2026
LMS launch · 20+ courses live
The Emergent learning platform went live with over twenty courses, AI-generated
quizzes, certificates and role-based mandatory training. Human rights, legal
compliance, SOPs, risk — the competence story made visible. Pavel endorsed with
hard deadlines and the all-hands launch landed the same week.
8 April 2026 · Milestone
ISO 45001 gaps closed — three days early · Stage 2 confirmed
The Friday 11 April internal target was met on Tuesday. All remaining 45001 clause
gaps closed through seven new procedures, the supplier ecosystem squared away, and
the system ready for the Libero ISO 45001 Stage 2 on-site audit on 21 April 2026
— confirmed on the certification body's side, flights booked.
Phase 07
Close-out
The conversation that started in October, finishing where it always should — together, in a room.
3 May 2026 · provisional
Shell MS Team close-out visit
Andy, Dennis and Neil return. Every finding walked through
with its evidence, every OFI answered, every commitment from the February CMP
demonstrated in practice. The chapter this portal was built for.
Date provisional · to be confirmed with Shell
Closing note
Six months ago this was a Teams call and a cold introduction. Today it's a management
system that's been stress-tested by three of the best auditors in the business, a
set of findings that were fair, and a close-out plan that we've delivered ahead of
plan on almost every item. That didn't happen by accident — it happened because
Shell's team asked the right questions, stayed patient through the answers, and
kept the conversation human throughout. The pages that follow are what came of it.
