06 Human Rights

The Voluntary
Principles, lived.

The Voluntary Principles on Security and Human Rights are the closest thing the private security industry has to a conscience. Shell knows it. Seagull Maritime knows it. This chapter is the evidence that we have not just read them — we have mapped them, embedded them in every live procedure, built the training that drives them into muscle memory, and made them mandatory for every person on our payroll from the bridge to the boardroom.

Read. Mapped. Embedded.

The Voluntary Principles, the International Code of Conduct for Private Security Service Providers, and the Montreux Document are not a decorative trinity bolted onto an existing management system. They are the ethical backbone of how Seagull Maritime thinks about armed operations. Every procedure that touches a weapon, an incident, a detention, or a client interaction is written through this lens — and every person who could conceivably act on our behalf is trained in what that lens requires of them.

Security operations conducted by private actors must respect human rights and humanitarian law, and nothing about being a maritime PMSC changes that obligation. If anything, the sea is where oversight is thinnest and the principles matter most.
01
The floor

Universal Declaration of Human Rights

The foundation. The baseline. The rights that every person carries with them regardless of flag, passport or the context of the interaction. We train on it because every decision a PCASP operator makes — from a challenge on a skiff to the treatment of a detained individual — can either uphold these rights or erode them.

Where it lives SM/TRG/DOC/001 PCASP HR Training
SM/TRG/DOC/002 Staff HR Training
SM/INT/POL/002 Code of Conduct
02
The operational standard

Voluntary Principles on Security & Human Rights

The VPSHR are the bridge between aspiration and operation. Risk assessment that factors in human rights impact, interactions with public security that preserve it, interactions with private security that enforce it. Referenced explicitly in our SOPs, RUF, Code of Conduct, Social Media Policy, Incident and Crisis Management procedure, and the DD Response Procedure.

Where it lives SM/OPS/SOP/001 IOR SOP
SM/OPS/PRO/001 Rules on the Use of Force
SM/INT/PRO/006 Incident & Crisis Management
03
The accountability layer

ICoCA & the Montreux Document

The International Code of Conduct for Private Security Service Providers turns the Voluntary Principles into auditable company-level obligations, and the Montreux Document codifies state and contractor obligations under international humanitarian law. Both are referenced directly in our Code of Conduct rebuild and our OCIMF Master Responses.

Where it lives SM/INT/POL/002 Code of Conduct
SM/SEC/DOC/001 OCIMF Master Responses
SM/SEC/PRO/002 DD Response Procedure

A brief gap analysis.

Honesty first. When the Shell audit landed, our human rights coverage was defensible but not exemplary — references existed, but they were scattered, under-emphasised, and nowhere near the centre of the training programme. The gap analysis below is the honest before-and-after, written without cosmetics.

Before · March 2026
What we had.
  • VPSHR referenced in passing in the legacy SOPs and the old Code of Conduct — present but not prominent, easy for a reviewer to miss and easier still for an operator to never encounter in training. Scattered
  • No dedicated human rights training course. Induction briefings touched the principles at a surface level but offered no depth, no assessment, and no completion record. Untested
  • Montreux Document not referenced by name in any live document. ICoCA mentioned but not tied into the procedural fabric of the management system. Incomplete
  • No formal mapping between the VPSHR framework and the procedures that should embody it. A compliance bypass was technically possible because the link was implicit, not explicit. Unmapped
  • No cross-reference in the Incident & Crisis Management procedure to how human rights considerations shape the response to a use-of-force incident. Missing link
After · April 2026
What we have.
  • VPSHR written explicitly into the IOR SOP, the RUF, the Incident & Crisis Management procedure, the Social Media Policy, and the DD Response Procedure. Not buried — titled, signposted, cross-referenced. SM/OPS/SOP/001 · PRO/001 · INT/PRO/006 · POL/008 · SEC/PRO/002
  • Two dedicated human rights training courses: one for PCASP operators framing the principles from the frontline, one for shore staff and management framing them from the oversight angle. Both mandatory, both tracked in the LMS, both assessed. SM/TRG/DOC/001 · SM/TRG/DOC/002
  • Code of Conduct fully rebuilt — twenty-five tracked changes including the Montreux Document, the ICoCA, and the VPSHR all named and anchored to procedural obligations. SM/INT/POL/002 (rebuild, Session 24)
  • A training and competence matrix making the human rights courses mandatory for every operational and shore role — twenty-one courses across forty-one personnel, with the LMS tracking completion, refresh dates, and failure alerts. SM/INT/REG/008 · learn.seagullmaritimeltd.com
  • NCR-003 raised against our own system to formally track the VPSHR integration across every affected document. Status: CA Implemented. Evidence captured in the NCR Register. SM/INT/REG/004 NCR Register

The hard proof.

Every claim above anchored to a live document, a live training course, or a live register entry. No promises, no roadmaps, no "planned for Q3". These are the receipts, and they are all in Chapter 07 · Documents if Shell wants to open any of them in full.

Training · Frontline
PCASP Human Rights Training
Twenty-eight-slide dedicated course building the three-layer model for armed operators. Mandatory for every PCASP on the Seagull roster. Assessed in the LMS, certificate issued on completion, refreshed annually.
SM/TRG/DOC/001
Training · Oversight
Staff & Management HR Training
Parallel twenty-eight-slide course reframed for shore staff and management — the oversight angle. Mandatory for every Seagull employee above the operator tier, including directors and the commercial team.
SM/TRG/DOC/002
Policy · Foundation
Code of Conduct rebuild
Twenty-five tracked changes in a full rebuild — VPSHR, ICoCA, Montreux Document, sanctions, legislation and cross-reference updates. The document that every employee signs on joining, now anchored to the modern ethical framework.
SM/INT/POL/002
Procedure · Armed ops
Rules on the Use of Force
Rebuilt with ten tracked changes including a dedicated VPSHR section, the ICoCA / Montreux fix, and the BMP5 → BMP-MS update. Backed by five form annexes covering acknowledgements, statements of understanding, release authorisations, and incident reports.
SM/OPS/PRO/001 + FORM/001–005
Procedure · Incident
Incident & Crisis Management
Incident response procedure with explicit human rights considerations written into the response flow — how a use-of-force incident is treated, how detained individuals are handled, how the crisis chain escalates.
SM/INT/PRO/006
Register · Competence
Training & Competence Matrix
Twenty-one courses mapped against three role categories across forty-one personnel, with the two human rights courses flagged as mandatory for every operational and shore role. LMS-tracked, with refresh cycles set at twelve months.
SM/INT/REG/008
NCR · Self-raised
NCR-003 · VPSHR integration
We raised a non-conformance against our own system to formally track the VPSHR integration across every affected document. Scored, actioned, closed. Status: CA Implemented.
SM/INT/REG/004 · NCR-003
DD · External
OCIMF Master Responses
Sixty-eight standard OCIMF questions answered with live human rights references — the document that goes out to every client and auditor asking about our ethical posture.
SM/SEC/DOC/001

The commitment.

Human rights training at Seagull Maritime is mandatory, not optional. Not a briefing. Not an awareness note. A full course, assessed, recorded, refreshed annually, and tied to a personnel-level completion record in the LMS. The PCASP course is mandatory for every armed operator. The staff course is mandatory for every director, manager, ops coordinator and administrative role.

If a person cannot show a current completion certificate on the Seagull LMS, they do not deploy, they do not dispatch, and they do not sign documents in the name of the company. Every watch. No exceptions.

This is not a compliance exercise. It is a statement about the kind of company Seagull Maritime intends to be — and, just as important, the kind of company we refuse to be.