Internal Shell documents from late 2012 reveal that the company formally requested and approved an exception to its global Health, Safety, Security, Environment and Social Performance (HSSE & SP) control framework. This exception allowed operations to continue on compromised pipelines in Nigeria, despite the pipelines failing to meet technical integrity standards. The application, filed by Arie Dijksman and endorsed by Pipeline Asset Manager Jurgen Janzen, acknowledged that Shell's Nigerian pipelines were classified as “red” under GAIR definitions due to numerous illegal connections installed by oil thieves. A single unauthorized tap, by definition, rendered a pipeline non-compliant and typically required immediate corrective action or shutdown.

Shell’s rationale for seeking the exception was that shutting down the system to remove all illegal taps would take considerable time and risk exacerbating the problem, as thieves often installed new connections during downtime. The company requested a temporary exception until December 2014, proposing to continue operations while alternative controls were put in place. This exception received approval at multiple levels: Ian Craig, Shell’s Executive Vice President for Upstream International Gas, signed off in December 2012; Group Process Safety Manager Paul Buijsinghl recommended the request later that month; and Global Discipline Lead Tony Paul gave final approval in March 2013. The documents emphasized that thorough risk assessments had been conducted, and that alternative controls would reduce risks to “As Low As Reasonably Practicable” (ALARP). Managers were specifically tasked with tracking this exception within Shell’s assurance systems and ensuring its reflection in the company’s annual Group Assurance Letter.

This approval underscores the extraordinary pressures Shell faced in Nigeria’s Niger Delta, where widespread sabotage and oil theft made strict compliance with global safety standards nearly impossible. By formally granting such exceptions, Shell effectively acknowledged that its pipelines were operating outside normal safety limits, yet chose to prioritize continued production over prolonged shutdowns. This decision highlights the inherent tension between corporate safety frameworks and the challenging realities of operating in conflict-prone regions, where economic imperatives, government revenues, and community unrest frequently clash with environmental and safety risks.

Adding to this context, earlier confidential internal emails from October 2008, reported by SaharaReporters, revealed sharp disagreements among senior Shell executives over whether to continue operating the Nembe Creek Trunk Line (NCTL) in Nigeria. Concerns were raised that this pipeline was also outside technical integrity standards and highly vulnerable to sabotage. Markus Droll, then Shell’s Technical Vice President, warned in these correspondences that the company was “pretty exposed” by its decision to keep the line running. He argued that the justification for not shutting down the supplying wells was weak and stressed that another “massive explosive attack” could force an immediate closure. Droll insisted on prioritizing the installation of Non-Return Valves (NRVs) to safeguard wells, alongside pipeline replacement, noting that sabotage could easily recur even after repairs.

Conversely, Ann Pickard, Shell’s Regional Executive Vice President for Africa at the time, acknowledged the risks but defended the decision to continue operations. In her email, she framed it as a choice between two risky paths, concluding that “the lower risk to both people and environment is to try and keep operating in the mode that is described.” While she agreed to begin purchasing NRVs, she maintained that continuing production was the safer option given the circumstances. These exchanges further highlight the tension between commercial imperatives and safety concerns. Droll underscored that the cost of installing shut-off measures was minor compared to the expense of replacing the pipeline, while Pickard emphasized the need to balance risks under the ALARP principle. These internal communications, circulated among top Shell officials in Lagos and Europe, clearly illustrate the precarious situation confronting the company in Nigeria’s oil-rich but volatile Niger Delta.