06-main-dossier.md - BDS-1000 Corporate Dossier: Shell Energy

Key Findings

• Economic: Shell plc supplied approximately 5% of Israeli crude oil imports between October 2023 and July 2024 through commercial trading, routing crude via Israeli refiners including Paz, Delek, Sonol, and Bazan Group, which operate petrol stations in OPT settlements.¹²
• Political: Paz Oil Company, divested by Shell in 2014, holds jet fuel supply contracts with the Israeli Ministry of Defence for seven Israeli Air Force bases through December 2026; Shell explicitly declined to respond to a BHRRC inquiry about fuel supply following the ICJ ruling.³¹
• Not found: No direct military or digital technology nexus identified for Shell Energy retail operations; Military and Digital both score 0.00.

Target Profile

Key Facts:

• Shell plc is the world’s largest LNG trader by volume, with operations in over 70 countries and approximately 93,000 employees (2023 annual report).⁸⁴
• Shell Energy UK was established following Shell’s £400 million acquisition of First Utility in 2018, rebranded to Shell Energy Retail Ltd.⁹¹⁰
• Shell Energy Australia was established following Shell’s AUD $617 million acquisition of ERM Power in 2020 (delisted); ERM Power was the leading C&I electricity retailer in Australia prior to acquisition.¹¹
• Shell plc fully exited its Gaza Marine offshore gas field equity in 2018; remaining equity holders are the Palestine Investment Fund (PIF) and Consolidated Contractors Company (CCC).⁸¹²¹³
• Shell divested Shell Israel to Paz Oil Company in 2014 for approximately USD $120 million.¹⁰
• Shell Energy UK sells its UK broadband customer base to Vonage/Telecom operator in 2023 as part of strategic focus on energy.¹⁴

Executive Summary

Shell Energy - comprising Shell Energy Retail Ltd (UK) and Shell Energy Australia Pty Ltd - is a downstream energy retail brand under Shell plc, one of the world’s largest integrated oil and gas companies. The company’s documented Israel/Palestine nexus is indirect and attenuated, stemming primarily from the historical and commercial legacy of Shell plc’s corporate structure rather than from Shell Energy’s own operations.

The Military audit found no public evidence of Shell Energy holding any contracts with Israeli Ministry of Defence, Israel Defence Forces, Israel Prison Service, or Israel Border Police.¹⁵ Shell Energy’s commercial mandate is domestic UK and Australian energy retail - supplying electricity, gas, and broadband to residential and business customers - and it is not structured as a defence procurement entity.⁹ No Shell Energy-specific export licence applications, end-user certificates, or government export control reviews related to dual-use sales to Israeli defence end-users were identified in available records.⁸

The economic and political nexus traces principally to Shell plc’s upstream and trading activities. Shell plc supplies approximately 5% of Israeli crude oil imports through commercial commodity trading, documented from October 2023 through July 2024.¹ Critically, Shell’s 2014 divestment of Shell Israel to Paz Oil Company - while reducing Shell plc’s direct Israeli exposure - created an indirect complicity pathway: Paz Oil operates petrol stations in at least 13 OPT settlement locations and holds jet fuel supply contracts with the Israeli Ministry of Defence for seven Israeli Air Force bases, including contracts extended through December 2026.³ This creates a chain through which Shell’s former Israeli operations now supply Israeli military infrastructure.

Shell plc has issued no public statement addressing Gaza, Palestine, or the Israel-Palestine conflict, and has not responded to a BHRRC inquiry about fuel supply for violent conflict following the ICJ ruling.⁴¹⁶¹⁷ Shell explicitly declined to respond to BHRRC’s inquiry about fuel supply following the ICJ ruling.¹⁷

The resulting BRS score of 143 / Tier E (Minimal) reflects this attenuated, indirect nexus. The dominant vectors are economic (crude oil supply to Israeli refiners that operate in OPT settlements) and political (Shell’s silence on the conflict, failure to engage ICJ-related inquiries). The military and digital vectors carry essentially zero weight, as no direct Shell Energy involvement in Israeli defence technology, procurement, or surveillance systems was documented.

Timeline of Relevant Events

Corporate Overview

Corporate Structure

Shell plc (formerly Royal Dutch Shell plc) is incorporated in England and Wales with its registered office at Shell Centre, London. Following a 2021 shareholder vote, Shell unified its dual Anglo-Dutch share structure and redomiciled entirely to the UK, dropping the “Royal Dutch” prefix.⁸ Shell is listed on the London Stock Exchange (primary), Euronext Amsterdam, and the New York Stock Exchange (ADR). The pre-2021 dual structure comprised Royal Dutch Petroleum (Netherlands, 60%) and The Shell Transport and Trading Company (UK, 40%), a structure dating to 1907.⁸

Shell Energy Retail Ltd is incorporated in England and Wales (Companies House registration number 02166905; originally First Utility Ltd, renamed Shell Energy Retail Ltd following Shell’s 2018 acquisition for approximately £400 million).⁹ The company is a direct wholly owned subsidiary of Shell plc and is headquartered in Hove, East Sussex.

Shell Energy Australia Pty Ltd is incorporated in Queensland, Australia (ACN 009 124 891; formerly ERM Power Ltd). ERM Power was an ASX-listed company prior to Shell’s 2020 acquisition; upon completion it was delisted and became a wholly owned subsidiary of Shell Energy Holdings Australia Pty Ltd, itself owned by Shell plc.¹¹

Shell Trading & Shipping is the intra-group entity through which both Shell Energy Retail and Shell Energy Australia conduct wholesale commodity procurement. Shell Trading is incorporated in the UK and is the world’s largest physical energy trading operation by volume.⁴

Israeli Entities and Franchise Relationships

Historical - Divested:

• Shell Israel Ltd (downstream fuels): Shell divested to Paz Oil Company in 2014 for approximately USD $120 million. No foundational or ongoing shareholding relationship between Shell plc and Israeli state entities has been publicly identified post-divestment.¹⁰

Indirect via Former Subsidiary:

• Paz Oil Company Ltd (now restructured as Paz Retail and Energy Ltd): Paz acquired Shell Israel’s downstream fuels business in 2014 and subsequently developed OPT settlement operations. Paz Retail and Energy Ltd operates petrol stations in at least 13 OPT settlement locations (Karnei Shomron, Alfei Menashe, Ma’ale Adumim, Ariel, Kiryat Arba, Mishor Adumim Industrial Zone, Shilat Junction, Ramat Eshkol, Gilo, Ramot, Pisgat Ze’ev, Tunnel Road, Katzrin, Merom Golan), plus Palestinian neighbourhoods al-Aizariya, Beit Hanina, and al-Sawana.³¹⁰ Paz Aviation Services (wholly owned subsidiary) holds a jet fuel supply contract with Israeli Ministry of Defence for seven Israeli Air Force bases (contract won 2016, extended through December 2026).³ Paz holds active fuel contracts with Israeli Civil Administration (Beit El settlement headquarters), DCL Gaza, Israel Police, and Israel Prison Service as of 2023–2024.³

Current - Trading Relationship:

• Shell plc supplies approximately 5% of Israeli crude oil imports through its commercial commodity trading operations. Shell crude routes through Israeli refiners Paz, Delek, Sonol, and Bazan Group - refiners that operate petrol stations in OPT settlements.¹² Shell crude is sourced from Azerbaijan, Kazakhstan, and Italy.¹²

Gaza Marine

Shell plc historically held 55–60% of the Gaza Marine offshore gas field (inherited on BG acquisition in 2016). This Palestinian asset was blocked from development by Israel since 2000. Shell fully exited its Gaza Marine equity in 2018; the remaining equity holders are the Palestine Investment Fund (PIF) and Consolidated Contractors Company (CCC).⁸¹²¹³ A June 2023 preliminary Israeli approval for an Egyptian EGAS/Cheiron-led development consortium did not involve Shell.¹²⁹¹⁸ The original 25-year PA licence (granted 1999) would have expired approximately 2024.¹²¹⁸

Domain Summaries

Military: Military

Mechanism of Involvement

The Military audit examined five pathways through which Shell Energy could be connected to Israeli military activities: direct defence contracting, dual-use products, heavy machinery and infrastructure, supply chain integration with defence primes, and logistical sustainment.

Direct Defence Contracting: No public evidence has been identified of any contract, tender award, framework agreement, or memorandum of understanding between Shell Energy (the UK energy retail subsidiary of Shell plc) and the Israeli Ministry of Defence (IMOD), the Israel Defence Forces (IDF), the Israel Prison Service, or the Israel Border Police.¹¹⁵ Shell Energy’s commercial mandate is domestic energy retail - supplying electricity, gas, and broadband to residential and business customers in the UK - and it is not structured or registered as a defence procurement entity.⁹ Shell plc operates in Israel primarily through upstream hydrocarbon extraction (Leviathan offshore gas field), involving commercial supply to civilian utility counterparties such as the Israel Electric Corporation.⁴¹ No Shell Energy-specific export licence applications, end-user certificates, or government export control reviews related to dual-use sales to Israeli defence end-users have been identified in available records.⁸

Dual-Use Products: Shell Energy’s core commercial offering - domestic and SME electricity, gas, and broadband supply within the UK - does not include products with recognised dual-use characteristics under standard export control classifications.⁹ No public evidence has been identified of Shell Energy manufacturing, marketing, or supplying ruggedised, tactical, mil-spec, or defence-grade product variants.² Shell plc’s broader lubricants, chemicals, and fuels divisions produce commodities that are inherently dual-use by virtue of their industrial nature, but no purpose-built, militarily specified, or contract-modified supply by Shell Energy to Israeli state defence or security bodies has been documented.²

Heavy Machinery and Infrastructure: Shell Energy is an energy retailer, not a manufacturer, distributor, or operator of heavy machinery, construction equipment, or engineering plant. No public evidence has been identified of Shell Energy equipment, vehicles, or machinery appearing in documented records of occupied territory construction activity, settlement infrastructure development, separation barrier maintenance, or military installation construction.³²¹ Shell plc’s upstream operations involve heavy offshore extraction infrastructure (drilling platforms, subsea pipelines, LNG terminals) as part of the Leviathan field, but no evidence connects this to OPT settlement or military installation construction.⁴¹

Supply Chain Integration with Defence Primes: No public evidence has been identified of Shell Energy providing components, sub-systems, raw materials, specialist manufacturing services, or technology to major Israeli defence prime contractors (Elbit Systems, Israel Aerospace Industries, Rafael, Israel Military Industries).⁴¹ Shell Energy’s supply chain is oriented around energy commodity procurement, grid balancing services, and broadband infrastructure - none of which represent inputs to Israeli defence prime weapons, platforms, or C4ISR supply chains.¹

Logistical Sustainment and Base Services: No public evidence has been identified of Shell Energy holding contracts to provide catering, transport, fuel supply, waste management, facilities management, telecommunications, or any other logistical sustainment or base support service to IDF bases, detention centres, border crossing infrastructure, or other Israeli security installations.⁴¹⁰ No evidence has been identified of Shell Energy service provision to installations located in the West Bank, Golan Heights, East Jerusalem, or the Negev region in a military or security context.³²¹

Strategic Platforms: No public evidence has been identified of any Shell Energy role in Israeli strategic defence platforms including Iron Dome, David’s Sling, Arrow missile defence, the F-35 programme, or the Merkava main battle tank series.⁴²⁰

Counter-Arguments and Evidence Limits

Shell Energy’s strongest counter-argument is structural: it is a downstream retail energy brand with no documented role in defence procurement, dual-use product supply, or military logistics. The Military audit found no evidence to overcome this baseline. The company’s commercial products (residential electricity, gas, broadband) are not weapons, components, or dual-use inputs to Israeli military systems.

The audit does note that Shell plc’s broader lubricants, chemicals, and fuels divisions produce commodities that are inherently dual-use by virtue of their industrial nature (hydraulic fluids, aviation fuels, marine fuels, industrial lubricants) and are available to military end-users as a matter of routine open-market commercial availability worldwide.² However, this generic availability does not constitute documented purposeful involvement with Israeli military supply chains.

The audit also notes that Shell plc operates LNG tanker fleets and participates in global energy trading and shipping as part of its integrated oil and gas business, but no evidence connects these shipping operations to Israeli military cargo movements, defence logistics, or arms shipment facilitation.¹²

Evidence limits: The Military audit relies on publicly available records, NGO databases (including Who Profits), UN databases, and government procurement databases. The absence of documented evidence does not constitute proof of absence. The UN HRC settlement database (A/HRC/43/71, February 2020) predates its coverage, and any subsequent amendments were not confirmable from available training data as of April 2026.²¹¹⁶ No court proceedings, judicial reviews, or legal challenges brought against Shell Energy concerning a defence supply relationship with Israel have been identified in available legal or civil society records.¹⁰⁸

Named Entities and Evidence Map

Digital: Digital

Mechanism of Involvement

The Digital audit examined Shell Energy’s technology stack, surveillance and biometric systems, cloud infrastructure, defence/intelligence sector relationships, and AI/autonomous systems for connections to Israeli military, intelligence, or surveillance technology.

Enterprise Technology Stack: Shell Energy’s retail and corporate operations are underpinned by Shell plc’s centralised procurement and IT governance frameworks, which span finance, supply chain, HR, and customer operations.⁴ Shell plc maintains one of the world’s largest SAP deployments, with Shell Energy retail billing and customer management systems operating within or alongside this broader SAP environment.⁴ Shell Energy UK and Australia have deployed Salesforce for customer relationship management, underpinning retail customer accounts, service requests, and digital engagement channels.¹ Shell plc has a long-standing strategic relationship with Microsoft; Azure is among the primary cloud platforms used for corporate workloads, and Shell Energy retail operations inherit this Microsoft dependency.² AWS is referenced in Shell’s public digital transformation communications as a cloud partner for data analytics and innovation programmes.¹⁵ Shell has historically engaged IBM for managed IT services, mainframe infrastructure, and digital transformation consulting.²⁰ Shell plc operates IT outsourcing relationships with Indian-headquartered service providers Wipro and Infosys, who deliver application management, infrastructure services, and digital development work globally.²⁰ Oracle database technology is embedded across Shell’s enterprise estate as part of legacy and transitional ERP/middleware layers.⁴

Surveillance, Biometrics, and Retail Technology: Shell Energy UK is a licensed smart meter installer and supplier under the UK’s SMETS2 rollout, communicating via DCC (Data Communications Company) infrastructure operated by Capita.¹¹ Shell Energy has marketed smart tariff and demand-response products in Australia and the UK that integrate with smart home devices, involving telemetry data collection from customer premises devices.²¹ No public evidence has been identified of Shell Energy deploying biometric identity verification for retail customers, operating proprietary surveillance or biometric systems beyond standard corporate physical security norms, or using facial recognition technology.¹¹

Cloud Infrastructure: Shell plc has publicly committed to a multi-cloud strategy with Microsoft Azure and AWS as primary hyperscaler platforms; Google Cloud Platform is also referenced in Shell’s data science and AI initiatives.²¹⁵ Shell Energy Australia’s retail operations are subject to Australian Privacy Act obligations with data storage in Australia and overseas under Shell plc’s global IT infrastructure.⁸ Shell Energy UK’s retail operations are subject to UK GDPR with data flows to EEA-based Shell entities conducted under UK Standard Contractual Clauses.¹² No specific sovereign cloud commitment (e.g., AWS Australia Regions with dedicated sovereignty guarantees) has been publicly identified for Shell Energy Australia’s retail workloads. No public evidence identified of Shell Energy or Shell plc participating in any government-mandated sovereign cloud programme (UKCloud, AWS GovCloud, or Australian Sovereign Cloud initiatives) specifically for energy retail operations.⁸¹²

Defence, Intelligence, and Security Sector Technology Relationships: No public evidence has been identified of Shell Energy (the retail brand) holding contracts with defence ministries, intelligence agencies, or security sector entities in Australia, the UK, or elsewhere.¹⁸ Shell plc at the corporate level holds energy supply contracts with government departments and defence facilities in the UK and Australia as part of its commercial energy supply portfolio, though specific inclusion of defence or intelligence sites is not publicly confirmed.¹⁸ Shell Energy Australia’s electricity generation assets and retail licence place it within the Australian Security of Critical Infrastructure Act 2018 regime, requiring relationships with the Australian Cyber Security Centre (ACSC) and cyber incident reporting - a regulatory security relationship rather than a commercial defence contract.⁹ Shell plc publicly references partnerships with major cybersecurity vendors including Microsoft (Sentinel/Defender), Claroty (OT security), and Palo Alto Networks for enterprise and operational technology security, extending across the Shell group including retail operations; no evidence of classified or intelligence-community-specific technology relationships has been identified.²

AI, Algorithmic, and Autonomous Systems: Shell plc has publicly invested in AI and machine learning across its business, including retail energy operations, applied to demand forecasting, asset optimisation, and customer analytics.¹⁶ Shell Energy Australia and UK have deployed or piloted algorithmic systems for customer churn prediction, dynamic pricing and tariff optimisation, and smart meter data analytics for consumption profiling and demand response.¹²¹ Shell plc has a documented commercial relationship with C3.ai for predictive maintenance and AI-driven operations across upstream and downstream assets; whether C3.ai applications extend specifically to Shell Energy retail operations has not been publicly confirmed.²³ Shell Energy UK has deployed AI-assisted customer service tooling including chatbot interfaces; specific vendor attribution has not been publicly disclosed.¹⁶ Shell Energy Australia participates in the National Electricity Market (NEM) and deploys automated bidding systems for wholesale electricity market participation governed by AEMO market rules.¹⁴ No public evidence identified of Shell Energy retail operations deploying autonomous physical systems (drones, robotics) in a retail energy context.¹⁶

Counter-Arguments and Evidence Limits

Shell Energy’s strongest counter-argument is that its documented technology relationships are standard commercial enterprise IT arrangements with global technology vendors - SAP, Salesforce, Microsoft, AWS, IBM, Oracle - that are ubiquitous across major corporations worldwide. The audit found no evidence that these relationships constitute supply chains for Israeli military or intelligence technology.

The smart metering infrastructure operates through the UK’s DCC network under Ofgem regulatory oversight and is part of the national SMETS2 rollout, not a proprietary Shell surveillance system.¹¹ The telemetry data collected through smart tariffs and demand-response products is consistent with standard UK and Australian energy retail data practices and subject to GDPR and Australian Privacy Act obligations respectively.⁸¹²

The critical infrastructure designation (SOCI Act in Australia) represents regulatory compliance obligations, not commercial defence contracts. The requirement to report cyber incidents to ACSC is a baseline security obligation for critical infrastructure operators, not evidence of defence technology supply.⁹

Evidence limits: The Digital audit notes that specific vendor attribution for Shell Energy UK’s AI-assisted customer service tooling has not been publicly disclosed. Shell Energy Australia’s Powersource energy management platform (inherited from ERM Power acquisition) represents a proprietary technology asset whose specific data processing architecture is not fully disclosed publicly.³ The audit acknowledges that Shell plc’s cloud adoption is governed through SITI’s global architecture standards, which apply down to business unit level including the Shell Energy retail brand, but the precise Israeli nexus within this technology stack is not separately documented.

Named Entities and Evidence Map

Economic: Economic

Mechanism of Involvement

The Economic audit examined Shell Energy’s supply chain, investment and capital exposure, operational presence, and corporate structure for economic nexus with Israeli military or settlement activities.

Supply Chain: Shell plc operates one of the world’s largest integrated hydrocarbon supply chains, encompassing upstream extraction, LNG liquefaction, shipping, and trading. Shell is the world’s largest LNG trader by volume.⁴ Shell’s LNG supply portfolio spans Australia (Queensland Curtis LNG, Prelude FLNG), the United States (Sabine Pass offtake, LNG Canada), Nigeria (NLNG), Trinidad, Qatar, and Oman.¹ Shell Energy Retail (UK) and Shell Energy Australia source electricity and gas through intra-group trading desks and third-party wholesale markets, structurally embedding their supply chains within Shell plc’s global commodity flows. Shell Energy Australia sources gas under long-term supply agreements from Australian basins (Cooper, Surat-Bowen, Perth) and uses Shell’s LNG re-gasification infrastructure.² Shell Energy UK sources electricity through Power Purchase Agreements with renewable generators and through Shell’s trading arm, marketing 100% renewable electricity supported by Renewable Energy Guarantee of Origin (REGO) certificates.²⁰

Israeli Supply Chain: No public evidence identified of Shell Energy Retail or Shell Energy Australia having direct supply chain relationships with Israeli-domiciled suppliers, contractors, or intermediaries. Shell plc historically held a stake in the Ramat Hovav industrial complex in Israel and was involved in Israel’s early offshore gas sector; however, Shell has divested most of its Israeli upstream interests.¹⁰ Shell divested Shell Israel to Paz Oil in 2014.¹⁰

Crude Oil Supply to Israel: Shell plc supplies approximately 5% of Israeli crude oil imports through its commercial commodity trading operations, documented from October 2023 through July 2024.¹ Shell crude is sourced from Azerbaijan, Kazakhstan, and Italy, and routes through Israeli refiners Paz, Delek, Sonol, and Bazan Group.¹² These refiners operate petrol stations in OPT settlements including Ma’ale Adumim, Ariel, Kiryat Arba, Kedumim, and occupied East Jerusalem.¹²²⁴ The Oil Change International November 2025 update documents ongoing Shell crude supply to Israel covering 12 months post-ICJ advisory opinion and approximately 11 months prior to the November 2024 ICC arrest warrants.¹²²

Investment and Capital: Shell plc reported full-year 2023 adjusted earnings of $28.3 billion and total assets of approximately $398 billion.⁸ Shell Energy Retail Ltd files accounts at Companies House with revenues in excess of £3 billion (year ending December 2022), wholly owned by Shell plc without independent external debt.⁹ Shell acquired ERM Power in 2020 for approximately AUD $617 million (approximately USD $430 million at the time); Shell Energy Australia is a wholly owned subsidiary.¹¹ Shell is the operator and 40% partner in LNG Canada (total project cost approximately CAD $40 billion), expected to commence first LNG exports in 2025.¹⁸ Following the 2014 divestment of Shell Israel, no material direct financial exposure to Israeli-domiciled assets has been publicly identified. No public evidence identified of Shell bond issuances specifically financing Israeli operations.¹⁰

Operational Presence: Shell Energy Retail is a mid-tier UK domestic energy supplier that absorbed the customer books of several failed suppliers during the 2021–2022 UK retail energy crisis.²⁰ Shell Energy Australia is the leading retailer to large commercial and industrial customers in Australia by contracted load.² Shell Energy Retail expanded into UK broadband and home telephony services, subsequently announcing the sale of its UK broadband customer base to Vonage/Telecom operator in 2023 as part of strategic focus on energy.¹⁴ Shell plc operates in more than 70 countries with approximately 93,000 employees; its integrated gas (LNG) segment is the largest earnings contributor.⁸ Shell holds a 17.9% interest in Abu Dhabi’s ADNOC through its stake in the Abu Dhabi Gas Industries (GASCO) joint venture and holds various interests in Omani gas and LNG projects; Shell has no publicly disclosed operational presence in Israel as of this audit’s date.¹

Corporate Structure: Shell Energy Retail Ltd is incorporated in England and Wales, a direct wholly owned subsidiary of Shell plc.⁹ Shell Energy Australia Pty Ltd is incorporated in Queensland, Australia, a wholly owned subsidiary of Shell Energy Holdings Australia Pty Ltd, itself owned by Shell plc.¹¹ Shell Trading & Shipping is the intra-group entity through which both Shell Energy Retail and Shell Energy Australia conduct wholesale commodity procurement; it is the world’s largest physical energy trading operation by volume.⁴ Shell plc (incorporated in England and Wales) is listed on LSE (primary), Euronext Amsterdam, and NYSE (ADR).⁸ Shell had a downstream fuels presence in Israel (Shell Israel Ltd) from the mid-20th century; divested to Paz Oil Company in 2014 for approximately USD $120 million.¹⁰ No foundational or ongoing shareholding relationship between Shell plc and Israeli state entities has been publicly identified post-divestment.¹⁰

Counter-Arguments and Evidence Limits

Shell Energy’s strongest counter-argument is structural: Shell Energy Retail and Shell Energy Australia are downstream retail brands with no direct operations in Israel. The company’s documented Israeli exposure is indirect, operating through two principal mechanisms: (1) Shell plc’s commercial crude oil trading - a commodity supply relationship with Israeli refiners that is indistinguishable from standard global energy market participation; and (2) the divested Shell Israel subsidiary now operating as Paz Oil Company under new ownership.

Regarding the crude supply nexus: Shell plc’s crude trading to Israeli refineries represents routine commodity market participation. Paz, Delek, Sonol, and Bazan Group are major Israeli energy companies operating primarily for the Israeli civilian market. The fact that some of their petrol station networks include OPT settlement locations does not reflect a Shell-specific decision to supply settlement operations - it reflects the commercial structure of the Israeli refined product market. Shell explicitly declined to respond to BHRRC’s inquiry about fuel supply for violent conflict following the ICJ ruling, but this non-response is not equivalent to documented purposeful settlement supply.¹⁷

Regarding the Paz Oil divestment: Shell divested its Israeli downstream operations in 2014, exiting the specific business that now supplies Israeli military operations and OPT settlements. Shell has no equity, board representation, or contractual control over Paz Oil Company’s subsequent business decisions. The argument that Shell “should have known” or bears residual responsibility for a former subsidiary’s later activities is a corporate attribution theory that the audit does not establish as documented fact.

Evidence limits: The Economic audit notes that Shell Energy’s renewable electricity claims are supported by Renewable Energy Guarantee of Origin (REGO) certificates, but the underlying UK grid mix is determined by the broader wholesale market.²⁰ The audit does not establish that Shell plc’s global LNG trading specifically routes cargoes to Israeli end-users - the 5% crude import figure is documented, but the refined product flows to OPT settlements from those crude inputs are documented at the refiner level (Paz, Delek, Sonol, Bazan), not attributed to Shell with specificity.¹²

Named Entities and Evidence Map

Political: Political

Mechanism of Involvement

The Political audit examined Shell’s corporate communications, operations in occupied territories, internal governance, brand heritage, lobbying activities, and executive footprint for political nexus with Israeli military or settlement activities.

Corporate Communications: Shell plc has issued no public press release, media statement, or social-media communication addressing Gaza, Palestine, or the Israel-Palestine conflict as of the date of this compilation.⁴¹⁶ Shell’s annual report risk-factor language references “the conflict in the Middle East” generically as a business risk but does not identify Gaza or Palestine specifically.⁴¹⁶ Shell’s publicly archived press releases include statements on the Russia-Ukraine conflict (March 2022, including apology, profit donation, and full exit announcement) and on the Iran conflict (March 2026, covering Qatar operations), but no Gaza-equivalent statement exists.⁴¹⁶²³ Shell explicitly declined to respond to a BHRRC inquiry about fuel supply for violent conflict following the ICJ ruling.⁴¹⁷ Shell issued no statement addressing the ICJ advisory opinion (July 2024) or ICC arrest warrants (November 2024) in relation to Gaza.⁴¹⁶²³

Operations in Occupied Territories: Shell plc has no confirmed corporate entity registered in Israel as a subsidiary.⁴ Shell’s Gaza Marine gas field equity was fully exited in 2018; the sole remaining equity holders are PIF and CCC.⁸¹²¹³ Shell plc is documented as a supplier of approximately 5% of Israeli crude oil imports (October 2023 – July 2024) via the Oil Change International/Data Desk August 2024 report; Shell crude routes through Israeli refiners Paz, Delek, Sonol, and Bazan Group, which operate petrol stations in OPT settlements.⁴¹² Paz Oil Company Ltd. (restructured to Paz Retail and Energy Ltd.) operates petrol stations in at least 13 OPT settlement locations and Palestinian neighbourhoods al-Aizariya, Beit Hanina, and al-Sawana.³¹⁰ Paz Aviation Services (wholly owned subsidiary) holds a jet fuel supply contract with Israeli Ministry of Defence for seven Israeli Air Force bases; the contract was won in 2016 and extended through December 2026.³ Paz holds active fuel contracts with Israeli Civil Administration (Beit El settlement headquarters), DCL Gaza, Israel Police, and Israel Prison Service as of 2023–2024.³

UN OHCHR Settlement Database: Shell plc is not listed in the UN OHCHR settlement database (A/HRC/60/19, 158 companies, September 2025).¹⁵²⁰ Paz Oil Company Ltd. was listed on the UN OHCHR settlement database from February 2020 (resolution A/HRC/31/36 iteration) but was delisted in the A/HRC/60/19 update (September 2025); footnote (i) of A/HRC/60/19 states “Formerly Paz Oil Company Ltd.” and indicates the restructured entity (Paz Retail and Energy Ltd.) was delisted following information that the new entity was no longer involved - despite conducting identical operations including OPT settlement petrol stations.¹⁵²⁰²¹

Legal Proceedings: Al-Haq filed a Dutch criminal complaint against Shell under the International Crimes Act for settlement complicity; the complaint was dismissed by the Dutch Public Prosecutor.¹⁵²⁰ Norway’s Government Pension Fund Global excluded Paz in May 2024 citing “unacceptable risk” of contributing to serious rights violations in the conflict.¹⁰

Internal Governance: James Hunkin (Shell investment manager) published a book titled The Gaza Marine Story: The Politics and Intrigue Behind Palestine’s Untapped Gas Wealth (2025) via LinkedIn; no HR disciplinary action against this publication was documented.⁶ One Shell US employee (Hammad Ali) posted pro-Palestine content on LinkedIn including IDF comparisons; no documented HR action against this post was found.⁶ No documented HR enforcement action, termination, or disciplinary proceeding against any Shell employee for pro-Palestinian speech or advocacy was identified.⁶ No independent reports, academic studies, or regulatory inquiries regarding Shell’s algorithmic moderation or editorial stances related to the Israel-Palestine conflict were identified.⁶

Lobbying and Advocacy: Shell USA Inc. is registered for US LDA lobbying disclosure; its 2024 Q1 and 2025 Q1 filings disclose lobbying on Venezuela/OFAC (Dragon gas field), NDAA §804, USMCA, maritime shipping, Section 232 tariffs, IEEPA, advanced recycling, and renewable energy/LNG.²⁵ No lobbying on Israel, boycott, BDS, or divestment legislation is disclosed in Shell’s US LDA filings.²⁵ Shell plc is registered in the EU Transparency Register (REG 05032108616-26) with estimated annual lobbying costs of €4,500,000–€4,999,999 (2025); no Israel, Palestine, boycott, or BDS-specific lobbying topics appear in Shell’s disclosed EU interests.²⁶ Shell’s position on the UK Economic Activity of Public Bodies (Overseas Matters) Bill (the “anti-boycott bill,” 2023–2024) is not documented in parliamentary Hansard transcripts or committee evidence sessions.²⁷²⁸

Shell Foundation: Shell Foundation (EIN 98-0368454) received $14.3M unrestricted and $10.9M restricted (FCDO) from Shell Group in FY2024 per its own accounts, with net assets of $672M.²⁹³⁰ No Israel-Palestine programme was documented in Shell Foundation’s available content.²⁹³⁰ Wael Sawan (Shell CEO from January 2023) appeared as an unpaid named Trustee of Shell Foundation on IRS 990 filings for FY2020, 2021, and 2022; he ceased appearing as trustee after FY2022.²⁹ No personal philanthropy vehicle controlled by Wael Sawan was identified.⁷

Executive Footprint: Andrew Mackenzie (Shell plc Chairman) is a named Director of the Mackenzie Family Foundation (EIN 20-5700615), a US 501(c)(3) private foundation with net assets of approximately $52–57M, on IRS 990-PF filings for FY2020–2024.⁵ No Israel-specific grant activity was confirmed from available 990 summaries for the Mackenzie Family Foundation.⁵ Wael Sawan has no identified personal philanthropy vehicle in Israel/Palestine-related causes.⁷ The “Sawan Foundation” (EIN 47-1431265) is an unrelated entity established in 2014 by Gurmej Sandhu in Alabama.⁷ No FIDF, JNF, KKL, CFI, AIPAC, or settlement-organisation donations by any named Shell plc executive or board member were documented.⁵²⁹⁷ Sir Nigel Sheinwald (Shell plc board member 2012–2021; chaired Safety, Environment and Sustainability Committee) is a former UK Ambassador to the United States; no FIDF/JNF/AIPAC/CFI affiliations were documented for Sir Nigel Sheinwald.²⁷

Boycott Campaigns: Shell was a target of anti-apartheid boycotts in the 1980s–1990s for South Africa operations; Shell’s UK petrol market share fell 6.6% during the boycott campaign.³¹ Current Gaza-related boycott campaigns explicitly invoke the anti-apartheid precedent against Shell.³¹ No active organized BDS campaign naming Shell Energy specifically was documented in the search period.³¹

Corporate Humanitarian Response: No Shell corporate humanitarian response to Gaza - including donations, crisis response programmes, or aid partnerships - was documented.¹⁶³⁰ Shell has not participated in or funded the Gaza Humanitarian Foundation (GHF).¹⁶³⁰

Shell Energy Stadium: Shell Energy Stadium (Houston Dynamo/Dash; naming rights held since January 2023) carries the Shell Energy brand; no evidence of Israeli Embassy co-sponsorship, CFI/AIPAC events, or Israeli community programming through this venue was identified.¹⁹

Counter-Arguments and Evidence Limits

Shell Energy’s strongest counter-argument on the political domain is that its actual corporate structure separates it from the documented Israeli nexus vectors. The company operates as a UK and Australian domestic energy retailer with no documented presence in Israel. The crude oil supply relationship - Shell plc’s largest documented Israeli economic vector - is a commodity trading activity indistinguishable from standard global energy market participation. Paz Oil Company’s settlement operations and IDF contracts are the actions of a separate corporate entity under new ownership since 2014.

Regarding Shell’s silence on Gaza: Shell has not issued statements on the Israel-Palestine conflict, but Shell has also not issued statements on numerous other geopolitical situations. The Political audit notes that Shell’s annual report risk-factor language references “the conflict in the Middle East” generically as a business risk, indicating the company acknowledges geopolitical risk from the region in its commercial assessment.⁴¹⁶ The absence of a Gaza-specific statement may reflect a corporate communications policy of not taking public positions on geopolitical conflicts unless directly implicated - not necessarily an indication of pro-Israel bias or active support for Israeli policies.

Regarding the Paz divestment creating indirect complicity: Shell has no equity, board representation, or contractual control over Paz’s subsequent activities. Paz’s acquisition of Shell Israel was a commercial transaction with Paz Oil Company - an Israeli company - acquiring an Israeli business. The subsequent development of OPT settlement petrol station operations and IDF jet fuel contracts reflects Paz’s own business decisions post-2014. Shell cannot be held responsible for a former subsidiary’s business development under new ownership.

Regarding Shell’s failure to respond to BHRRC’s inquiry: Non-response to a civil society inquiry does not constitute evidence of wrongdoing. Shell may have declined to respond on jurisdictional, legal, or commercial confidentiality grounds without endorsing the premise of the inquiry.

Evidence limits: The Political audit notes that the “Sawan Foundation” referenced in some records is an unrelated entity established in 2014 by Gurmej Sandhu in Alabama - a false attribution requiring clarification.⁷ No grant recipient data was available in extracted ProPublica summaries for the Mackenzie Family Foundation; no Israel-specific programme was confirmed, but absence of confirmation in 990 summaries does not constitute proof of absence.⁵ The UN OHCHR delisting of Paz Retail and Energy Ltd in September 2025 despite identical OPT operations raises questions about the database’s methodology, but does not reflect on Shell’s current activities.¹⁵²⁰²¹

Named Entities and Evidence Map

BDS-1000 Score (V4)

• V_MAX: 2.00 Sum_OTHERS: 1.47
• BRS Score: 143 Tier: E (Minimal)

Score drivers: Political (2.00) is V_MAX, driven by the combination of crude oil supply to Israeli refiners that operate in OPT settlements (high magnitude) and the documented political exposure through Paz Oil (Shell’s former Israeli subsidiary now supplying Israeli Air Force bases). The Political magnitude and proximity scores reflect Shell plc’s systemic role as a global commodity trader - even a 5% share of Israeli crude imports represents material economic participation in an Israeli refining sector with documented OPT settlement operations. The Economic score (1.47) reflects the economic scale of Shell plc’s global operations and the documented indirect pathway through Paz. Military and Digital are both zero: no documented Shell Energy involvement in Israeli military technology, procurement, or dual-use supply chains.

The Tier E (Minimal) classification reflects the attenuated, indirect nature of Shell Energy’s documented nexus. The company’s retail operations in the UK and Australia have no documented Israel/Palestine involvement. The dominant vectors trace to Shell plc’s commodity trading activities and the legacy of a divested Israeli subsidiary - not to Shell Energy’s own operational decisions.

Method: Scale-free Impact × magnitude/proximity; evidence-only from domain audits; human-vetted scores applied.

Methodology Note

• Evidence-only standard: Every claim in this dossier traces to one or more of the four domain audits (Military, Digital, Economic, Political). Where audits found nothing, this dossier states “No public evidence identified.” No speculative claims, extrapolations, or unverified allegations are included.
• Scale-free Impact: I scores capture the type of activity (weapons, funding, infrastructure, political support) regardless of scale. Higher I reflects more severe activity types; lower I reflects peripheral or indirect activity.
• Magnitude (M) and Proximity (P): M captures scale, volume, or reach. P captures directness of relationship to end recipient (Israeli military, settlement population, or conflict-affected civilian). Both are applied after I; product I × M × P = V-domain.
• Temporal rule: Divested or exited operations are discounted. Shell’s 2014 divestment of Shell Israel to Paz Oil and its 2018 exit from Gaza Marine reduce - but do not eliminate - its indirect ongoing exposure through Paz Oil’s subsequent activities.
• Entity attribution: No transitive guilt. Shell Energy Retail and Shell Energy Australia are assessed on their own documented activities; Shell plc’s broader activities are assessed separately. Paz Oil Company’s post-2014 activities are documented as a causal chain - Shell’s divested Israeli subsidiary now supplies Israeli military infrastructure - but this is an indirect nexus, not direct Shell involvement.
• “No public evidence identified”: Used throughout where domain audits conducted checks and found nothing. This is a methodological discipline, not a proof of absence; it means the available public record does not support a finding, not that the activity is definitively absent.

End Notes

Document compiled: BDS-1000 OSINT Research Corpus Company: Shell Energy Final human-vetted scores applied per V4 protocol. Evidence-only standard maintained throughout.