INDEX / DIRECTORY / SHELL ENERGY

Shell Energy

Energy & Utilities 117 CITED SOURCES UPDATED 2026-05-18
BDS-1000 Score 80 /1000 E Tier E — Limited

Target Profile


Executive Summary

Shell Energy — encompassing the UK retail brand Shell Energy Retail Ltd, the Australian commercial retail entity Shell Energy Australia Pty Ltd, and their ultimate parent Shell plc — scores 80 out of 1,000 on the BDS-1000 index, placing it firmly in Tier E, the lowest tier of documented involvement. This score reflects a company with residual, historical, and indirect economic ties to Israel but no identified military, digital, or active political engagement.

The dominant scoring driver is V-ECON, anchored by two confirmed relationships: Shell plc’s historical downstream fuels presence in Israel (Shell Israel Ltd, divested to Paz Oil in 2014 for approximately USD 120 million) and its participation in Eastern Mediterranean LNG offtake arrangements linked to the Leviathan offshore gas field via NewMed Energy (formerly Delek Drilling).12 Both relationships are commercial and civilian in character; neither involves defence procurement, weapons, or occupation infrastructure.

V-POL contributes a modest secondary score, driven exclusively by a documented asymmetry in corporate communications: Shell issued a named condemnation of Russia’s invasion of Ukraine and announced its exit from Russian operations, but issued no comparable public statement regarding the Gaza conflict.34 This selective silence places Shell in the “Double Standard” band of the political rubric, though the low magnitude of a passive omission substantially constrains the domain score.

V-MIL and V-DIG both score zero. Across all military sub-categories — defence contracting, dual-use supply, weapons systems, occupation infrastructure, logistical sustainment — no public evidence of any Shell Energy involvement was identified. In the digital domain, Shell Energy is exclusively a buyer and user of third-party technology; the Customer Cap rule applies throughout, and no Israeli-origin software or technology provision to Israeli state or security bodies was found.

The principal evidentiary uncertainty is the current operational status of the Leviathan-linked offtake arrangements. If confirmed as ongoing and material, the BDS-1000 score could rise to approximately 87–108 — still Tier E. The 2014 divestment of Shell Israel remains the most material historical economic relationship; post-divestment, Israel is a marginal market relative to Shell’s USD 280–300 billion annual revenue base.


Timeline of Relevant Events

DateEvent
Mid-20th centuryShell Israel Ltd established; Shell operates downstream petrol retail within Israel
2014Shell divests Shell Israel Ltd to Paz Oil Company for approximately USD 120 million 2
2018Shell acquires UK domestic energy supplier First Utility for approximately £400 million; rebrands as Shell Energy 5
2019–2020Shell acquires ERM Power (Australia) for approximately AUD 617 million; establishes Shell Energy Australia 6
2021Shell plc unifies Anglo-Dutch dual share structure; redomiciles entirely to UK, eliminating Dutch golden share 7
May 2021Dutch court (Milieudefensie v. Shell) orders Shell to cut carbon emissions 45% by 2030; Shell appeals 8
February 2022Shell issues named statement announcing exit from Russian operations following Ukraine invasion, characterising it as a “senseless military attack”; takes approximately USD 5 billion in Russian asset write-downs 34
2023Shell Energy UK sells broadband customer base to third-party telecoms operator; refocuses on energy retail 9
October 2023–presentGaza conflict commences; no Shell public statement specifically addressing the conflict identified 10
2024–2025Status of Shell’s Leviathan-linked LNG offtake arrangements with NewMed Energy not confirmed in available records 111

Corporate Overview

Shell Energy is the downstream retail and commercial energy brand of Shell plc, one of the world’s largest integrated energy companies. The brand encompasses two principal operating entities: Shell Energy Retail Ltd in the United Kingdom and Shell Energy Australia Pty Ltd, both wholly owned subsidiaries of Shell plc.

Shell plc is incorporated in England and Wales and listed primarily on the London Stock Exchange, with secondary listings on Euronext Amsterdam and the New York Stock Exchange (ADR). Following its 2021 corporate unification — which collapsed the legacy dual Anglo-Dutch structure into a single UK entity — no state holds a golden share or preferential governance instrument in Shell plc.7

Shell Energy Retail Ltd (Companies House registration 02166905, formerly First Utility Ltd) was established via Shell’s 2018 acquisition of First Utility and subsequently rebranded. It serves residential and SME customers in the UK across electricity, gas, and (until 2023) broadband.5 Shell Energy Australia Pty Ltd was created through the 2019–2020 acquisition of ERM Power, giving Shell a leading position in Australian commercial and industrial electricity retail as well as an electricity generation portfolio.6

The two retail entities sit within Shell plc’s global integrated structure and source commodity supply through Shell Trading & Shipping, Shell’s intra-group trading arm and the world’s largest physical energy trading operation by volume.12 Shell Energy’s commercial mandate is entirely downstream retail; it is not a defence contractor, technology developer, or manufacturer.

Shell plc reported full-year 2023 adjusted earnings of USD 28.3 billion and total assets of approximately USD 398 billion. Shell Energy Retail Ltd reported revenues in excess of £3 billion for the year ending December 2022. Israel constitutes a marginal market in Shell’s global footprint following the 2014 divestment of Shell Israel; no active upstream or retail operations within Israel have been publicly disclosed as of the audit date.7


Domain Summaries

V-MIL: Military

Mechanism of Involvement

Shell Energy has no identified mechanism of military involvement in relation to Israel or the Occupied Palestinian Territories. The audit’s exhaustive survey across six discrete sub-categories — direct defence contracting, dual-use products, heavy machinery and construction, supply chain integration with defence primes, logistical sustainment and base services, and munitions and weapons systems — returned negative findings throughout.

Shell Energy Retail Ltd and Shell Energy Australia Pty Ltd are structured as downstream energy retailers. Their commercial mandate — supplying electricity, gas, and (formerly) broadband to residential and business customers — does not intersect with defence procurement or military supply chains.13 Neither entity is registered as a defence procurement vehicle, appears in Israeli Ministry of Defence tender databases, or is listed in SIBAT (Israel’s Defence Export and Cooperation Directorate) export directories.14

The only Shell-group activity with any Israeli connection identified in the military audit is Shell plc’s participation in the Leviathan offshore gas field consortium, which involves commercial supply arrangements to the Israel Electric Corporation (IEC), the Israeli state-linked civilian utility.1 This relationship is correctly classified as a civilian commercial energy transaction: the IEC is an electricity generating and distribution utility, not a defence entity. The gas offtake arrangement does not constitute defence procurement under any standard classification, and no evidence characterises it as such in audit sources or in Who Profits documentation.1

No Shell entity appears in any procurement database, official government announcement, or corporate disclosure linking it to the Israeli Ministry of Defence, the Israel Defence Forces (IDF), the Israel Prison Service, or the Israel Border Police.14 No joint ventures, memoranda of understanding, or framework agreements with Israeli defence bodies have been identified in public records.

The dual-use analysis warrants careful treatment. Shell plc’s broader upstream operations produce commodities — aviation fuels, marine fuels, hydraulic fluids, industrial lubricants — that are inherently available to military end-users through open commercial markets worldwide. However, open-market commercial availability of general industrial commodities is categorically distinct from purpose-built, militarily specified, or contract-modified supply. No Shell Energy-specific export licence applications, end-user certificates, or government export control reviews related to dual-use sales to Israeli defence or security end-users have been identified.15 No UK government decisions to grant, deny, suspend, or revoke export licences specifically for Shell Energy products destined for Israeli military end-users appear in the UK strategic export controls licensing database.15

On heavy machinery and construction: Shell Energy is an energy retailer with no manufacturing, distribution, or operation of heavy machinery. Shell plc’s offshore extraction infrastructure at the Leviathan field involves offshore drilling platforms and subsea pipelines. No evidence connects any such infrastructure to the construction or maintenance of Israeli military installations, settlements, or the separation barrier in the Occupied Palestinian Territories.1 The OHCHR database of business enterprises with activities in Israeli settlements (A/HRC/43/71) does not list Shell Energy as a named entity in available records.16

No supply of components, sub-systems, raw materials, or technology to Israeli defence prime contractors — Elbit Systems, Israel Aerospace Industries, Rafael Advanced Defense Systems, or Israel Military Industries — has been identified.1 Shell Energy’s supply chain is oriented around energy commodity procurement and grid balancing, not towards the weapons, platforms, or C4ISR supply chains of Israeli defence primes.1

Counter-Arguments and Evidence Limits

The most substantive counter-argument is the inherent dual-use character of hydrocarbons. Shell plc is the world’s largest LNG trader; its fuel products reach military users globally through open commercial markets. An analyst could argue that Shell’s contribution to Israel’s energy security indirectly enables IDF operational capacity. The audit acknowledges this indirect linkage but classifies it as incidental market exposure rather than purposive military supply: there is no documented contract specifying Israeli military end-use, no end-user certificate, and no evidence of contract modification for military specification.15

A second limitation concerns the completeness of procurement database coverage. The Israeli MoD tender database and SIBAT directories are not fully publicly accessible, and absence from publicly available records does not guarantee absence from classified or restricted procurement. This is a genuine evidential gap; however, absent positive evidence, it does not support an elevated score.

A third limitation is temporal: the OHCHR settlement database (A/HRC/43/71) dates from February 2020 and any successor amendments were not confirmable from available training data. Shell’s position in any updated listing cannot be confirmed or excluded.

For the score to change materially in V-MIL, positive evidence would need to emerge of: a direct IDF or IMOD supply contract; an end-user certificate linking Shell products to Israeli military use; or Shell equipment appearing in documented records of occupation infrastructure construction. None of these conditions is currently met.

Named Entities and Evidence Map

EntityTypeRelevanceEvidence Status
Shell Energy Retail LtdUK subsidiaryAudit target — energy retailerNo military involvement identified
Shell Energy Australia Pty LtdAU subsidiaryAudit target — energy retailerNo military involvement identified
Shell plcParent groupUltimate entity; Leviathan gas supply to IECCommercial civilian supply only
Shell Trading & ShippingIntra-group entityGlobal energy trading armNo Israel military supply identified
Israel Electric Corporation (IEC)Israeli state utilityCivilian gas offtake counterpartyCommercial utility, not defence
Israeli Ministry of Defence (IMOD)Israeli state defenceChecked for contractsNo relationship identified 14
Israel Defence Forces (IDF)Israeli militaryChecked for supplyNo relationship identified 1
SIBATIsraeli defence exports directorateChecked for Shell listingNot listed 14
Elbit SystemsIsraeli defence primeChecked for supply chain integrationNo relationship identified 1
Israel Aerospace Industries (IAI)Israeli defence primeChecked for supply chain integrationNo relationship identified 1
Rafael Advanced Defense SystemsIsraeli defence primeChecked for supply chain integrationNo relationship identified 1
Who Profits Research CenterCivil society databaseLists Shell plc re: Leviathan/fuel supplyCommercial context only 1
OHCHR A/HRC/43/71UN settlement databaseChecked for Shell Energy listingNot listed in available records 16
UK Strategic Export Controls databaseUK government licensingChecked for Shell Energy export licencesNo Shell Energy Israel defence licence identified 15

V-DIG: Digital

Mechanism of Involvement

Shell Energy scores zero in V-DIG. The Customer Cap rule — which constrains the score of any entity that is exclusively a buyer or user of third-party technology rather than a provider of technology to third parties — applies comprehensively throughout this domain. Shell Energy does not sell, license, or provide technology to Israeli state bodies, security agencies, military units, or Israeli-domiciled technology firms.

Shell Energy’s enterprise technology stack is large and complex, sourced through Shell plc’s centralised procurement and IT governance frameworks. It encompasses SAP S/4HANA ERP infrastructure, Salesforce CRM platforms for retail customer management, Microsoft Azure and M365 for cloud and productivity workloads, AWS for data analytics, Oracle database layers, and IT outsourcing relationships with Wipro and Infosys.1718 Every one of these relationships positions Shell Energy as a customer and consumer of technology, not a developer or supplier of technology to external parties. None of the vendors identified in the enterprise stack are Israeli-origin firms, and no Israeli-origin software or platform has been identified within Shell Energy’s technology infrastructure.

The smart metering programme merits specific attention. Shell Energy UK is a licensed SMETS2 smart meter installer and supplier under the UK’s national rollout programme. Smart meters communicate via the Data Communications Company (DCC) network, operated by Capita under Ofgem regulatory oversight, and Shell Energy collects half-hourly consumption data from customer premises.19 This constitutes a domestic data collection programme operating within a UK regulatory framework. It has no identified Israeli dimension — no Israeli firms are involved in the DCC network or Shell Energy’s smart meter supply chain as identified in available records.

Shell plc’s AI and algorithmic deployment covers customer churn prediction, dynamic pricing optimisation, smart meter data analytics, and wholesale market automated bidding in the Australian NEM.20 Shell plc also holds a documented commercial relationship with C3.ai for predictive maintenance and AI-driven operations.21 These AI applications are oriented towards commercial energy operations; no application to Israeli state surveillance, security, or intelligence functions has been identified.

The 2021 Accellion FTA data breach is the most significant digital security event in the audit record. The CLOP ransomware group exploited a zero-day vulnerability in Shell’s Accellion File Transfer Appliance instance, exfiltrating personal data and confidential company files. Shell confirmed the breach affected its global IT estate, though Shell Energy retail customer data was not specifically confirmed as affected.22 This incident is a cybersecurity compliance matter unrelated to Israeli operations.

Shell Energy Australia’s obligations under Australia’s Security of Critical Infrastructure Act 2018 (SOCI Act) require mandatory cyber incident reporting to the Australian Cyber Security Centre (ACSC).23 This is a regulatory compliance relationship with a government cybersecurity authority — not a commercial technology provision relationship. It does not constitute a defence or intelligence sector engagement and does not affect the V-DIG score.

The UK NIS Regulations 2018 impose equivalent cybersecurity obligations on Shell Energy’s UK operations. These are similarly mandatory regulatory compliance requirements, not commercial relationships.23

Counter-Arguments and Evidence Limits

The principal counter-argument is the opacity of large enterprise technology stacks. Shell plc operates one of the world’s largest SAP deployments and extensive cloud infrastructure across Microsoft Azure and AWS. It is not possible to exhaustively audit every software component, library, or SaaS integration for Israeli origin from publicly available records. The possibility that a sub-component or vendor relationship in the supply chain has Israeli origins or connections cannot be entirely excluded.

A second argument concerns Shell plc’s public sector energy supply in the UK. Shell Energy has supplied electricity to public sector organisations through framework agreements.24 The specific inclusion of defence or intelligence facilities in this public sector book has not been publicly confirmed. If Shell Energy holds a supply contract with, for example, a UK signals intelligence facility, this would represent energy provision to an intelligence-sector customer — though it would remain a commodity energy sale rather than a technology provision relationship and would not fall within V-DIG’s scope.

A third limitation is the absence of published data on Shell Energy’s AI vendor stack for customer-facing tools, including chatbot and digital engagement platforms. Specific vendor attribution has not been publicly disclosed, leaving open the question of whether any AI tooling has Israeli origins.

For the V-DIG score to change materially, evidence would be required of: Shell Energy providing technology (software, data analytics, AI services) to Israeli state, security, or military bodies; equity investment in Israeli technology firms; or Israeli-origin software embedded in Shell Energy’s customer-facing systems in a defence-relevant capacity. None of these conditions is currently evidenced.

Named Entities and Evidence Map

EntityTypeRelevanceEvidence Status
Shell Energy Retail LtdUK subsidiaryAudit targetCustomer/user of technology only
Shell Energy Australia Pty LtdAU subsidiaryAudit targetCustomer/user of technology only
Shell plc / SITIParent group / IT entityEnterprise technology governanceCustomer/user of technology only
SAPERP vendorCore enterprise platformShell is customer 17
SalesforceCRM vendorRetail customer management AU and UKShell is customer 18
Microsoft (Azure / M365)Cloud and productivity vendorPrimary cloud and productivity stackShell is customer 25
Amazon Web Services (AWS)Cloud vendorData analytics and innovation workloadsShell is customer 26
Wipro / InfosysIT outsourcing vendorsApplication and infrastructure managementShell is customer 27
C3.aiEnterprise AI vendorPredictive maintenance and AI operationsShell is customer 21
Capita / DCCUK smart meter network operatorSMETS2 data communicationsRegulatory infrastructure; no Israeli dimension identified
CLOP ransomware groupThreat actor2021 Accellion FTA breachSecurity incident; no Israeli dimension 22
Australian Cyber Security Centre (ACSC)Government authoritySOCI Act compliance relationshipMandatory regulatory obligation 23
AEMOAustralian energy market operatorNEM algorithmic bidding rulesMarket compliance; no Israeli dimension 28
OfgemUK energy regulatorConsumer standards and smart meter obligationsRegulatory compliance 29

V-ECON: Economic

Mechanism of Involvement

Shell Energy’s economic relationship with Israel operates through two confirmed channels: a historical direct presence (Shell Israel Ltd, active through most of the 20th century, divested 2014) and a residual commercial trading relationship linked to Israeli offshore gas (Leviathan field offtake via NewMed Energy, current status unconfirmed for 2024–2025).

Shell Israel Ltd was Shell’s downstream fuels subsidiary operating petrol stations and fuel distribution within Israel. This constituted a direct operational presence — a subsidiary physically domiciled and trading in Israel — representing the most material form of economic integration. Shell divested this entity to Paz Oil Company in 2014 for approximately USD 120 million, terminating its direct retail and fuels presence in the country.2 Post-divestment, no Shell subsidiary is identified as actively domiciled or operationally present within Israel.

The residual economic relationship is the Leviathan-linked LNG offtake. Shell plc holds or held an offtake arrangement with NewMed Energy (formerly Delek Drilling), an Israeli company holding equity stakes in the Leviathan and Tamar offshore gas fields in Israel’s Exclusive Economic Zone.11 This constitutes a direct bilateral commercial contract between Shell (via Shell Trading & Shipping) and an Israeli counterparty. The mechanism is transactional: Shell purchases gas volumes from Israeli-domiciled NewMed Energy, generating revenue flows into the Israeli gas economy. This is not a passive or incidental market exposure — it is a named bilateral agreement — but it is also not equity investment, technology transfer, or operational presence within Israel.

The Who Profits Research Center lists Shell in its database in connection with fuel supply operations in Israel, noting the fuel supply relationship to Israeli state infrastructure.1 The most recent confirmed Who Profits data predates 2020; ongoing status is unknown. This listing reinforces the assessment of Shell as having a documented economic relationship with Israeli commercial and infrastructure counterparties, though the characterisation is of a commercial supply relationship rather than investment or partnership.

Shell’s economic relationship with Israel is further contextualised by Shell’s Eastern Mediterranean gas interests more broadly. Shell plc holds interests in LNG and gas supply arrangements across the Eastern Mediterranean, and its LNG portfolio spans global offtake agreements.12 The Israeli-linked component of this portfolio is real but marginal relative to Shell plc’s global revenues of USD 280–300 billion annually. Israel does not constitute a strategic market for Shell; it is one commercial counterparty among many in a globally diversified trading portfolio.

The scoring reflects this structure: I=3.0 (Direct Sales/Sustained Trade) for the confirmed bilateral offtake relationship; M=3.50 (Minor Recurring) to reflect confirmed existence of the relationship but uncertainty about current scale and continuity; P=5.50 (Direct Commercial Contract) to reflect that the Leviathan offtake is a named bilateral contract with an Israeli counterparty, placing proximity above pure market-level exposure but below the Strategic Partner or Joint Venture bands that would require equity stakes or operational integration. Together these inputs yield a V-ECON domain score of 0.83.

The 2014 divestment is analytically significant: it represents a deliberate corporate decision to exit direct Israeli market presence, reducing Shell’s economic relationship from direct operational subsidiary (highest proximity) to trading-desk-level offtake arrangement (moderate proximity). This trajectory — from higher to lower engagement — is a mitigating factor in interpreting the current score.

Shell plc’s 2025 exposure to the US tariff environment is noted in the audit as an indirect economic consideration: the Trump administration’s tariff regime (25% on Canadian and Mexican imports, cumulative 145% on Chinese goods as of April 2025) creates upstream cost pressures and affects global LNG pricing dynamics.3031 This exposure is structurally unrelated to Israeli operations and does not affect V-ECON scoring.

Counter-Arguments and Evidence Limits

The principal evidentiary gap is the current operational status of the Leviathan offtake. The audit explicitly notes this was not confirmed for 2024–2025. If the offtake arrangement has lapsed, been restructured, or assigned to a non-Shell counterparty following NewMed Energy’s own corporate evolution, the residual economic relationship with Israel would be reduced to historical record only. In that scenario, M would decrease, and V-ECON could fall to approximately 0.4–0.6, reducing the composite BRS score by approximately 10–15 points.

Conversely, if the offtake is confirmed as ongoing and at material volume, M could reasonably rise to 4.0–5.0, increasing V-ECON to approximately 1.34–1.68 and BRS to approximately 87–108 — still firmly Tier E.

A second counter-argument concerns Who Profits’ scope. The Who Profits database listing references Shell in the context of fuel supply; however, the most recent data is pre-2020 and post-divestment of Shell Israel. The current basis for that listing is ambiguous — it may reflect legacy franchise arrangements or residual Shell-branded supply agreements that were not part of the 2014 Paz Oil divestiture. Without updated confirmation, this element of the economic relationship cannot be precisely characterised.

A third limitation is the opacity of Shell Trading & Shipping’s global commodity flows. Shell is the world’s largest LNG trader by volume; cargoes are fungible and allocated through a global trading desk. Identifying the precise economic value of Israeli-directed trades within this volume is not possible from public records, meaning the magnitude assessment is inherently imprecise.

For the score to change materially upward, evidence would be required of: confirmed ongoing Leviathan offtake at material volumes; equity investment in Israeli-domiciled energy or other companies; or re-establishment of direct operational presence in Israel. Downward revision would follow confirmation of offtake termination and absence of any other active commercial relationship.

Named Entities and Evidence Map

EntityTypeRelevanceEvidence Status
Shell Energy Retail LtdUK subsidiaryAudit target; UK retail energyNo direct Israeli economic activity identified
Shell Energy Australia Pty LtdAU subsidiaryAudit target; AU commercial retailNo direct Israeli economic activity identified
Shell plcParent groupLeviathan offtake; historical Shell IsraelConfirmed historical; current offtake status uncertain 211
Shell Trading & ShippingIntra-group trading entityWholesale commodity procurement arm; offtake counterpartyDirect contract with NewMed Energy 12
Shell Israel LtdFormer subsidiaryDownstream fuels; divested 2014Divested to Paz Oil ~USD 120M 2
Paz Oil CompanyIsraeli buyerAcquired Shell Israel 2014Divestiture counterparty 2
NewMed Energy (formerly Delek Drilling)Israeli companyLeviathan/Tamar gas field equity holder; offtake counterpartyConfirmed relationship; current status uncertain 11
Israel Electric Corporation (IEC)Israeli state utilityGas supply counterparty under Leviathan commercial arrangementsCivilian utility; commercial transaction 1
ERM Power (now Shell Energy Australia)Former ASX-listed companyAcquired 2019–2020; AUD 617MOperational in Australian NEM 6
Who Profits Research CenterCivil society databaseDocuments Shell fuel supply in IsraelPre-2020 data; ongoing status unconfirmed 1
Australian Energy Regulator (AER)Regulatory bodyShell Energy Australia complianceRegulatory relationship 32
OfgemUK energy regulatorShell Energy UK complianceRegulatory relationship 29
LNG CanadaMajor capital projectShell 40% operator; CAD 40B projectNo Israeli relevance; context only 33

V-POL: Political

Mechanism of Involvement

Shell Energy scores in V-POL on a single, well-documented finding: a corporate communications asymmetry between Shell’s public response to Russia’s 2022 invasion of Ukraine and its silence on the Gaza conflict that commenced in October 2023.

When Russia invaded Ukraine in February 2022, Shell plc issued a named public statement condemning the invasion as a “senseless military attack” and announced its intention to exit Russian oil and gas operations, including the Leviathan-scale Sakhalin-II LNG project, ultimately taking approximately USD 5 billion in asset write-downs.34 This response was proactive, named, and commercially costly: Shell voluntarily forfeited material Russian revenues and assets in service of a public political position.

No comparable public statement has been identified in connection with the Gaza conflict. Shell’s conflict-adjacent communications default to generic human rights language embedded within annual and sustainability reporting cycles, affirming adherence to the UN Guiding Principles on Business and Human Rights without geographic specificity to Israel or Palestine.3435 No named condemnation, no operational exit announcement, and no named public expression of concern regarding the Gaza conflict has been identified across Shell’s public communications channels, corporate press releases, CEO statements, or annual report commentary.10

This asymmetry is the mechanism of political involvement: Shell’s selective silence constitutes a choice — whether deliberate or by institutional default — to apply a different standard of corporate political engagement to the two conflicts. The BDS-1000 rubric classifies this as the “Double Standard” band within V-POL Impact, reflecting the documented gap between public stances on comparable humanitarian situations rather than any active political engagement in support of Israeli state policies.

It is important to define what this finding is not. Shell has not issued statements of support for Israeli government policies or IDF operations. Shell has not made financial contributions to Israeli state-aligned political organisations, Friends of the IDF (FIDF), the Jewish National Fund (JNF), or equivalent bodies.3410 Shell has not engaged in lobbying directed at Israel-Palestine policy, anti-BDS legislation, or the Taylor Force Act in the US Congress.36 Shell executives have made no identified public statements, social media posts, or signed open letters addressing the Gaza conflict in any direction. There is no evidence of Brand Israel participation, acceptance of Israeli state honours, or involvement in “Start-Up Nation” public diplomacy campaigns. The entire V-POL score rests on the communications asymmetry alone.

Shell’s Eastern Mediterranean commercial activities — participation in Israeli offshore gas conferences and trade events — are noted in the audit but classified as commercial industry participation rather than state-sponsored public diplomacy.35 Attendance at industry forums where commercial gas interests are discussed is not in itself a political act.

The scoring structure reflects the limited nature of this finding. I=2.50 (lower end of the Double Standard band, 2.1–3.0) reflects that the asymmetry is real and documented but that Shell’s actual political engagement is entirely passive — an absence of statement rather than a presence of action. M=1.50 (Very Low, 1.0–2.0) reflects that the magnitude of a non-statement by a non-media energy company is inherently limited; Shell does not operate content platforms and its communications influence in the Israel-Palestine domain is negligible. P=8.50 (High, Direct Actor) reflects that Shell itself is the entity that controls its own corporate communications — there is no structural distance or intermediary — and the non-act is therefore directly attributable to Shell’s own institutional decisions.343

Counter-Arguments and Evidence Limits

The strongest counter-argument to the V-POL score is that corporate silence on any given geopolitical conflict is the norm rather than the exception, and that Shell’s Ukraine response was anomalous rather than that its Gaza silence is anomalous. Under this reading, the existence of the Ukraine statement raises the baseline against which all subsequent silences are measured, potentially overstating the significance of the Gaza non-statement as a political act. The audit acknowledges this: the scoring band is the lowest within the Double Standard range (I=2.50 rather than I=3.0), and M is constrained to Very Low to reflect the passive character of the omission.

A second counter-argument is that internal Shell deliberations on the Gaza conflict may exist but are not publicly accessible. Absence of a public statement does not confirm absence of internal human rights review, supply chain due diligence, or executive consideration. The audit explicitly notes this limitation: “Internal documents of this nature are not publicly accessible, and absence of evidence here does not confirm absence of internal activity.”10 However, for BDS-1000 purposes, the relevant criterion is corporate communications posture — what Shell has chosen to say publicly — not internal deliberation.

A third limitation is the confirmation of Shell’s current Leviathan offtake status. If that relationship were confirmed as terminated, a reasonable argument exists that Shell’s public silence is consistent with its having already disengaged commercially, reducing the political significance of the communications asymmetry. Conversely, if the offtake is ongoing, the absence of any statement on Gaza while maintaining commercial ties with Israeli energy companies becomes more salient.

For the V-POL score to change materially upward, evidence would be required of: active lobbying in support of Israeli policy positions; financial contributions to Israeli state-aligned organisations; executive public advocacy in support of Israeli government actions; or Shell’s formal participation in Brand Israel or state-sponsored public diplomacy programmes. None of these conditions is evidenced. The score could decrease to zero if the Ukraine statement were retracted or if Shell were to issue a comparable statement on Gaza, which would eliminate the asymmetry basis.

Named Entities and Evidence Map

EntityTypeRelevanceEvidence Status
Shell plcParent groupAuthor of Ukraine statement; absent Gaza statementCommunications asymmetry confirmed 34
Wael SawanCEO, Shell plc (from Jan 2023)Corporate spokesperson; no Gaza statements identifiedNo Israel-Palestine advocacy found 734
Sinead GormanCFO, Shell plcSenior executiveNo Israel-Palestine advocacy found
Shell Energy Retail LtdUK subsidiaryBrand; no independent political communicationsNot separately relevant 13
NewMed EnergyIsraeli companyCommercial counterparty; Eastern Med conferencesCommercial industry participation 11
Who Profits Research CenterCivil society databaseDocuments Shell in fuel supply contextCommercial context; database listing confirmed 1
BDS MovementCivil society campaignShell not a named primary targetNo formal BDS designation confirmed 37
Business & Human Rights Resource CentreCivil society monitorTracks Shell corporate conductNo specific Gaza finding on record 10
Friends of the IDF (FIDF)Israeli state-aligned NGOChecked for Shell contributionsNo relationship identified 34
Jewish National Fund (JNF)Israeli state-aligned NGOChecked for Shell contributionsNo relationship identified 34
UN Guiding Principles (UNGPs)International frameworkReferenced in Shell sustainability reportingGeneric adherence language only 3435
US Senate Lobbying Disclosure databaseRegulatory databaseChecked for Shell Israel-related lobbyingNo Israel-Palestine lobbying identified 36
OHCHR settlement databaseUN databaseChecked for Shell listingNot listed; offshore assets outside territorial scope 38

Cross-Domain Counter-Arguments and Evidence Limits

The dominant cross-domain limitation is the relationship between V-ECON and V-POL evidence: the Leviathan offtake is simultaneously the primary economic relationship and the implicit commercial context for Shell’s political silence. If the offtake has lapsed, both the V-ECON score and the contextual weight of the V-POL communications asymmetry are reduced. Confirmation of the offtake’s current status is the single most material outstanding evidential question for the composite score.

A second cross-domain consideration is the distinction between Shell plc and its Shell Energy retail subsidiaries. The audit correctly maintains this distinction: the Leviathan gas relationships, the Shell Israel divestment, and the Ukraine/Gaza communications asymmetry all operate at the Shell plc level. Shell Energy Retail Ltd and Shell Energy Australia Pty Ltd have no independently identified Israel-related activities. This means that a consumer or institution engaging specifically with the Shell Energy retail brand — rather than with Shell plc as a commodity trading or upstream entity — is engaging with entities that have no documented direct Israeli involvement.

A third cross-domain limit concerns the pre-2020 vintage of several civil society data sources. The Who Profits listings most directly relevant to V-ECON and V-POL are confirmed only to pre-2020 periods. The OHCHR settlement database also predates 2020. Given the degree of corporate change at Shell between 2018 and 2025 (First Utility acquisition, ERM Power acquisition, corporate unification, Russia exit), the absence of post-2020 civil society confirmation of Israeli-linked activities is a genuine evidential gap rather than a clean negative.


Named Entities and Evidence Map

EntityTypeDomainsKey Finding
Shell Energy Retail LtdUK retail subsidiaryV-MIL, V-DIG, V-ECON, V-POLNo direct Israeli engagement across all domains
Shell Energy Australia Pty LtdAU retail subsidiaryV-MIL, V-DIG, V-ECON, V-POLNo direct Israeli engagement across all domains
Shell plcUK-incorporated parentAll domainsLeviathan offtake; Shell Israel divestment 2014; Ukraine/Gaza asymmetry
Shell Trading & ShippingIntra-group trading entityV-ECONDirect bilateral trading counterparty for Leviathan offtake
Shell Israel LtdFormer subsidiary (divested 2014)V-ECON, V-POLDownstream fuels; sold to Paz Oil ~USD 120M
Paz Oil CompanyIsraeli buyerV-ECONAcquired Shell Israel 2014
NewMed Energy (formerly Delek Drilling)Israeli gas companyV-ECON, V-POLLeviathan/Tamar field; offtake counterparty; current status unconfirmed
Israel Electric Corporation (IEC)Israeli state utilityV-MIL, V-ECONCivilian gas supply counterparty; commercial transaction
ERM PowerFormer ASX-listed AU companyV-ECON, V-DIGAcquired 2019–2020; AUD 617M; now Shell Energy Australia
Who Profits Research CenterCivil society databaseV-MIL, V-ECON, V-POLLists Shell re: fuel supply and Leviathan; pre-2020 data
BDS MovementCivil society campaignV-POLShell not a primary named target
Wael SawanGroup CEO, Shell plcV-POLNo Israel-Palestine advocacy identified
Sinead GormanCFO, Shell plcV-POLNo Israel-Palestine advocacy identified
SAPERP technology vendorV-DIGShell is customer
SalesforceCRM technology vendorV-DIGShell is customer
Microsoft (Azure/M365)Cloud and productivity vendorV-DIGShell is customer
Amazon Web ServicesCloud vendorV-DIGShell is customer
C3.aiEnterprise AI vendorV-DIGShell is customer
OfgemUK energy regulatorV-DIG, V-ECONRegulatory oversight; complaint and compliance data
Australian Energy Regulator (AER)AU energy regulatorV-DIG, V-ECONRegulatory oversight
ACSC / SOCI ActAU cyber authority / legislationV-DIGMandatory regulatory compliance only
OHCHR A/HRC/43/71UN settlement databaseV-MIL, V-POLShell not listed; offshore assets outside scope
SIBATIsraeli defence exports directorateV-MILShell not listed
ClientEarth / MilieudefensieEnvironmental civil societyV-DIG, V-ECONClimate litigation against Shell plc; unrelated to Israeli operations

BDS-1000 Score

DomainIMPV-Score
V-MIL0.000.000.000.00
V-DIG0.000.000.000.00
V-ECON3.003.505.500.83
V-POL2.501.508.500.46

Composite BRS: 80 / 1,000 — Tier E

V-ECON is the dominant domain (V-MAX = 1.179). V-POL contributes to the composite as a secondary domain, discounted by the 0.2 multiplier applicable to non-dominant domains under the BRS formula (Sum_OTHERS × 0.2 = 0.107). V-MIL and V-DIG contribute nothing to the composite.

The V-ECON inputs reflect: direct bilateral commercial sales relationship (I=3.0, Direct Sales/Sustained Trade band); minor recurring magnitude with uncertain current scale (M=3.50); and a direct commercial contract with an Israeli counterparty via Shell Trading & Shipping (P=5.50). The V-POL inputs reflect selective silence as a passive non-act: double standard band (I=2.50); very low magnitude for an omission by a non-media entity (M=1.50); and high proximity because Shell itself controls its own communications (P=8.50).


Confidence, Limits, and Open Questions

High confidence — V-MIL (zero) and V-DIG (zero): Evidence coverage is thorough across all sub-categories. The Customer Cap rule for V-DIG and the complete absence of defence contracting or military supply evidence for V-MIL are well-supported by multiple independent source types.

Moderate confidence — V-ECON (0.83): The confirmed anchors — Shell Israel divestment 2014, Who Profits listing, Eastern Med gas participation — are solid. The primary uncertainty is the Leviathan offtake’s current status. Score would remain Tier E under any plausible resolution of this uncertainty.

High confidence — V-POL (0.46): The Ukraine/Gaza communications asymmetry is clearly documented. Band placement (Double Standard) and the constrained magnitude scoring (Very Low) are both well-grounded.

Open questions requiring resolution for score refinement:

  1. Is the Leviathan-linked LNG offtake arrangement with NewMed Energy currently active as of 2024–2025? If confirmed at material volumes, M-ECON could rise to 4.0–5.0 and BRS to approximately 87–108.
  2. What is the current basis for the Who Profits listing — does it reflect a post-2020 confirmed relationship or legacy data from the pre-divestiture period?
  3. Has the OHCHR settlement database been updated post-2020, and if so, does it include any Shell entity?
  4. Does Shell Energy UK’s public sector supply book include defence or intelligence facilities in a confirmed and publicly documented capacity?

For institutions, investors, or consumers conducting due diligence:

Shell Energy scores 80/1,000 (Tier E), indicating minimal documented direct engagement with Israel across military, digital, economic, and political domains. The BDS-1000 framework does not mandate specific action at Tier E; recommended responses should be calibrated to the validated score, evidence base, and institutional risk appetite.

Given the moderate confidence uncertainty in V-ECON, institutions for whom any confirmed ongoing Israeli commercial relationship is a threshold concern should seek current confirmation of the Leviathan offtake status before finalising their assessment. The existing score is conservative (anchored to confirmed historical data); an active and material offtake would increase the score but not change the tier.

Given the V-POL selective silence finding, institutions or consumers for whom consistent corporate human rights communications standards are a decision criterion should note the documented Ukraine/Gaza asymmetry. This is a communications governance issue, not evidence of operational complicity, and its weight is appropriately reflected in a V-POL score of 0.46 rather than a higher domain contribution.

For civil society researchers and advocacy organisations:

The most productive evidential gap to close is the current status of Shell plc’s commercial relationship with NewMed Energy and the Leviathan gas field. Confirmation or denial of active offtake would materially clarify the economic dimension. Updated Who Profits research covering the 2020–2025 period would also resolve the ambiguity around the basis of Shell’s current database listing.

For Shell Energy itself:

The V-POL finding is the most directly addressable element of the score. The communications asymmetry between the Ukraine response and the Gaza silence is documented and publicly verifiable. If Shell’s position is that the two situations are not comparable on the basis of its commercial exposure or contractual obligations, a public explanation of that reasoning would replace the current “selective silence” characterisation with a defined and reviewable corporate position, which would be assessed differently under the rubric.


End Notes

Footnotes

  1. Who Profits Research Center, Shell company profile — https://whoprofits.org/company/shell/ 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

  2. Haaretz, Shell sells Israeli unit for $120 million (2014) — https://www.haaretz.com/business/2014-04-29/ty-article/shell-sells-israeli-unit-for-120-million/0000017f-e4c3-d7b2-a77f-e6cb8b850000 2 3 4 5 6

  3. Shell plc Annual Report 2022 — https://reports.shell.com/annual-report/2022/ 2 3 4 5

  4. Shell plc, intent to exit Russian oil and gas (2022) — https://www.shell.com/news-and-insights/newsroom/news-and-media-releases/2022/shell-announces-intent-to-exit-russian-oil-and-gas.html 2 3 4

  5. Shell completes acquisition of First Utility (2018) — https://www.shell.co.uk/media/2018-media-releases/shell-completes-acquisition-of-first-utility.html 2

  6. Shell Energy Australia, company history — https://www.shell.com.au/business-customers/shell-energy/about-shell-energy/our-history.html 2 3

  7. Shell plc Annual Report 2023 — https://reports.shell.com/annual-report/2023/ 2 3 4

  8. Milieudefensie v. Shell climate ruling — https://www.milieudefensie.nl/actueel/english/shell-must-halve-co2-emissions-by-2030

  9. Shell Energy broadband sold to telecoms provider (2023) — https://www.ispreview.co.uk/index.php/2023/06/shell-energy-broadband-to-be-sold-to-telecom-provider-in-uk.html

  10. Business & Human Rights Resource Centre, Shell — https://www.business-humanrights.org/en/companies/shell/ 2 3 4 5

  11. Oxford Energy, Israel’s offshore gas fields — https://www.oxfordenergy.org/publications/israels-offshore-gas-fields/ 2 3 4 5

  12. Shell plc, LNG overview — https://www.shell.com/energy-and-innovation/natural-gas/liquefied-natural-gas-lng.html 2 3

  13. Shell Energy UK, about us — https://www.shellenergy.co.uk/about-us 2

  14. SIBAT, Israeli defence exports directorate — https://sibat.mod.gov.il/ 2 3 4

  15. UK Government, strategic export controls licensing data — https://www.gov.uk/government/collections/strategic-export-controls-licensing-data 2 3 4

  16. OHCHR, A/HRC/43/71 database of business enterprises in Israeli settlements — https://www.ohchr.org/en/documents/thematic-reports/ahrc4371-database-all-business-enterprises-paragraph-96-report-independent 2

  17. SAP, Shell customer testimonial — https://www.sap.com/uk/customer-testimonials/energy/shell.html 2

  18. Salesforce, Shell Energy customer story — https://www.salesforce.com/au/customer-success-stories/shell-energy/ 2

  19. Shell Energy UK, smart meters — https://www.shellenergy.co.uk/smart-meters

  20. Shell plc, digitalisation and digital transformation — https://www.shell.com/energy-and-innovation/digitalisation/digital-transformation.html

  21. C3.ai, Shell customer profile — https://c3.ai/customers/shell/ 2

  22. Shell plc, data security incident notification (2021) — https://www.shell.com/media/news-and-media-releases/2021/shell-notified-of-data-security-incident.html 2

  23. Australian Government, Security of Critical Infrastructure Act 2018 — https://www.homeaffairs.gov.au/nat-sec/files/security-critical-infrastructure-act-2018.pdf 2 3

  24. Shell Energy UK, public sector business — https://www.shellenergy.co.uk/business/public-sector

  25. Microsoft, Shell digital transformation partnership (2021) — https://news.microsoft.com/2021/06/17/shell-and-microsoft-expand-partnership-to-accelerate-shells-digital-transformation/

  26. AWS, Shell case study — https://aws.amazon.com/solutions/case-studies/shell/

  27. Wipro, Shell case study — https://www.wipro.com/energy/shell-case-study/

  28. AEMO, National Electricity Market — https://aemo.com.au/energy-systems/electricity/national-electricity-market-nem

  29. Ofgem, supplier compliance data — https://www.ofgem.gov.uk/check-if-energy-supplier-is-following-the-rules 2

  30. White House, reciprocal tariff executive order (April 2025) — https://www.whitehouse.gov/presidential-actions/2025/04/regulating-imports-with-a-reciprocal-tariff-to-rectify-trade-practices-that-contribute-to-large-and-persistent-annual-united-states-goods-trade-deficits/

  31. Bloomberg, China 84% retaliatory tariffs on US goods (April 2025) — https://www.bloomberg.com/news/articles/2025-04-10/china-hits-back-at-us-tariffs-with-84-levy-on-american-goods

  32. AER, compliance and enforcement register — https://www.aer.gov.au/consumers/my-energy-bill/complain-about-your-energy-business/compliance-and-enforcement

  33. LNG Canada, project overview — https://www.lngcanada.ca/project/overview/

  34. Shell plc Sustainability Report 2023 — https://reports.shell.com/sustainability-report/2023/ 2 3 4 5 6 7

  35. Shell plc, human rights policy — https://www.shell.com/sustainability/environment-and-society/human-rights.html 2 3

  36. US Senate Lobbying Disclosure Act database — https://lda.senate.gov/system/public/ 2

  37. BDS Movement, target companies — https://bdsmovement.net/target-companies

  38. OHCHR, HRC session database of business enterprises — https://www.ohchr.org/en/hr-bodies/hrc/sessions/database-business-enterprises