Shell Energy

Key Findings

• Economic: Shell plc’s FY2023 Form 20-F Exhibit 8.1 lists Ravin AI Ltd (Ramat Gan), an Israeli AI vehicle-inspection company, as a 36% related undertaking at 31 December 2023. It was seeded by Shell Ventures in 2019. The holding is absent from the 2024 and 2025 exhibits, with no disposal record found, so its current status is unknown.^{1, 2, 3, 4}
• Economic: Oil Change International attributes about 5% of Israel’s crude imports to Shell-produced oil (October 2023 to July 2024). The 35% figure in circulation is the combined share of six majors, not a Shell-only share.^{5, 6}
• Political: Shell declined to comment to BHRRC on 10 September 2024 about oil supply to Israel and the ICJ ruling, and did not reply to Rai 3 “Report” in May 2026. Its February 2022 Gazprom exit statement is the contrast on which the Double Standard score rests.^{7, 8, 9}
• Not found: No public evidence identified of any Shell Energy contract with the Israeli military, any Israeli-origin technology in Shell Energy’s stack, or any Shell presence in settlements. The Gaza Marine interest was divested in 2018, and the UK retail business was sold in 2023.^{5, 10, 11}

Target Profile

Key Facts:

• Shell Energy Retail (UK and Germany) was sold by Impello Limited, a subsidiary of Shell Petroleum Company Limited, to Octopus Energy Group. The sale was announced on 1 September 2023 and completed on 1 December 2023.^{10, 17}
• Shell Energy Australia is a subsidiary of Shell Australia and was formerly ERM Power.¹⁴
• The Israel-related allegations located name Shell plc or Shell upstream units, not a Shell Energy entity.⁵

Executive Summary

“Shell Energy” is a brand, not a single Israel-facing entity. The audits found no Shell Energy entity with offices, sales, contracts or technology deployments in Israel or the occupied territories. The documented nexus sits mainly at Shell plc group level and is economic and political, not military or digital.¹³

The strongest vector is economic. First, Shell plc’s Exhibit 8.1 shows a 36% interest in Ravin AI Ltd at 31 December 2023, following Shell Ventures’ 2019 seed investment. It is a minority related-undertaking interest. The Ravin entry does not appear in the 2024 and 2025 exhibits, but the exhibits give no reason and no disposal record was found, so the current status is unknown.^{1, 2, 3, 4} Second, Oil Change International attributes about 5% of Israel’s crude imports (October 2023 to July 2024) to Shell-produced oil. Third, Greenpeace Italia and Rai 3 “Report” (May 2026) report that Eni said one of three Taranto crude shipments toward Israel was handled by Shell. These are NGO and broadcaster findings, not regulatory or judicial findings. The Shell-handled cargo is undated and its buyer is unnamed.^{6, 8}

The political record is a documented contrast. Shell announced its exit from Gazprom partnerships in February 2022, but declined to comment to BHRRC on 10 September 2024 about supply to Israel and the ICJ ruling, and did not reply to Rai 3 in 2026. This is a silence-based finding.^{7, 8, 9}

Not supported by evidence: any contract with the IDF or Israeli Ministry of Defence, supply to defence primes, militarised products, Israeli technology in Shell Energy’s systems, settlement operations, or listing of Shell in the materials read on the UN settlement database. That last point is not established for the full database. Oil Change International’s later updates (November 2025, September 2026) do not name Shell in the pages read.^{18, 19, 20} The Gaza Marine interest was divested in 2018 and the UK retail business was sold in 2023. The result is BRS 283, Tier D (Moderate Complicity), driven by Economic (V = 3.22).

Timeline of Relevant Events

Corporate Overview

Shell Energy Retail Limited was founded as First Utility, a spin-out from First Telecom (company number 05070887, incorporated 2004). Shell acquired it on 28 February 2018 and rebranded it in March 2019. It was sold to Octopus effective December 2023 and is now Octopus Energy Operations 2 Limited.^{12, 14} Shell New Energies Holding Limited was notified as a person with significant control of Shell Energy UK Limited from 3 July 2023.

Shell Energy Australia (formerly ERM Power, acquired November 2019) is a subsidiary of Shell Australia. It lists business electricity, gas, environmental products and the Powershop residential brand, and the page does not mention Israel or defence.¹³ The 2023 Exhibit 8.1 lists Shell Energy entities in Australia, Europe, Germany, Italy and Canada, and no Shell Energy entity in Israel. The only Israel entry is Ravin AI Ltd.¹ The audits do not identify which Shell entity holds the Ravin stake.

Group entities with a documented nexus include BG Great Britain Limited (Gaza Marine seller in 2018) and Shell E&P Italia S.p.A. (25% of the Tempa Rossa joint venture, per Greenpeace Italia). A 2012 trade page gives Total 75% and Shell 25%, which differs from Greenpeace’s Total 50%, Shell 25%, Mitsui 25%.^{8, 32}

Domain Summaries

Military: Military

Mechanism of Involvement

Military score is 0.00. The only military-adjacent material is third-party. Greenpeace Italia attributes Ministry of Defence or air force supply contracts to the Israeli buyers Bazan and Paz, and Eni said one of three Taranto crude cargoes toward Israel was handled by Shell (undated, buyer unnamed). Two of the three went to Paz.⁸ A Seasalvia tanker loading at Taranto (24 to 28 September 2025) was reported by L’Indipendente and Shipping Italy as chartered by Shell. Its destination is disputed: Ashkelon per the harbour-master account, Egypt as the official destination per Meteoweb, and Greece per Il Foglio. The union claimed the cargo was for Israeli military aviation. Other outlets do not mention a Shell charter, and no source ties the ship to the Report cargoes.^{27, 28, 33, 29}

Counter-Arguments and Evidence Limits

No public evidence identified of any Shell contract, tender or partnership with the Israeli Ministry of Defence, IDF or defence primes, of SIBAT listings, militarised product variants, munitions roles, export-licence actions or legal proceedings. AFSC does not show that Shell oil reaches military or settlement fuel supplies. Military supply is not inferred from crude availability.⁵ Eni said it acted only as terminal operator and that Shell did not reply to Report, but no Shell statement was found either way.⁸ The SOMO jet-fuel briefing names Paz, Valero and Overseas Shipholding, not Shell.³⁴ The UN Special Rapporteur coverage reviewed does not name Shell.³⁵

Named Entities and Evidence Map

Shell plc, Shell E&P Italia, Eni, TotalEnergies EP Italia (told Report it was not involved), Mitsui E&P Italia B, Thenamaris (Seasalvia owner), Paz and Bazan (downstream buyers).^{8, 27}

Digital: Digital

Mechanism of Involvement

Digital score is 0.00. The only technology link is Shell’s equity in Ravin AI Ltd, an Israeli computer-vision vehicle-inspection firm, and the sources describe Shell as an investor, not a user. In 2019 a Shell executive said Shell would “continue to seek opportunities to work with the team to bring Ravin AI to our network of customers”, which is a statement of intent and not a documented deployment.^{4, 36} Shell Ventures also took part in the December 2022 funding round of RepAir (described as Israeli), and Shell US Gas and Power, LLC announced up to $3m in milestone-contingent funding in January 2025. No payment or current equity is evidenced.³⁷

Counter-Arguments and Evidence Limits

No public evidence identified of Israeli-origin technology in Shell Energy’s stack, of cloud or Nimbus participation, of Israeli R&D centres, or of Shell AI supplied to Israeli state bodies. Ravin’s named customers are commercial (car dealers, rental, insurance), and no Israeli state customer is identified.³⁶ Shell Energy’s platform changes (Octopus Kraken) concern a business Shell no longer owns, and no Israeli component in Kraken is described.¹⁰ Shell’s AWS and SLB arrangements are group upstream workflows with no Israeli element.

Named Entities and Evidence Map

Ravin AI Ltd, Shell Ventures, RepAir Carbon US Inc., Octopus Energy and Kraken, Energy One, Pico Venture Partners. H2Pro (a Technion spin-off) was a finalist in Shell’s 2020 New Energy Challenge. The audits note no Shell investment, and the Technion lists other corporate investors.³⁸

Economic: Economic

Mechanism of Involvement

Economic drives the score (I = 6.10, M = 3.80, P = 6.80, V = 3.22). The vectors are:

• Equity: a 36% associate interest in Ravin AI Ltd at 31 December 2023, absent from later exhibits (status unknown).^{1, 2, 3}
• Crude supply attribution: Oil Change International lists Shell at 5% of Israel’s crude supply; AFSC dates the figure to October 2023 to July 2024.^{5, 6} BHRRC cites Shell’s partial ownership of the Caspian Pipeline Consortium and a 30-kiloton Val d’Agri cargo (Shell holds 39%), about 1% of Israel’s total.⁷
• Taranto cargoes as above, after the July 2024 ICJ opinion window, though the Shell-handled cargo is undated.⁸
• Gaza Marine: the interest was divested in April 2018. Pre-sale stake reports conflict (55%, 60%, 90%) and the audits do not reconcile them.^{11, 23, 39}
• Reported Leviathan and Aphrodite gas talks (2017 to 2018), with no signed deal evidenced [pre-2020].²²

Counter-Arguments and Evidence Limits

Shell’s strongest defence rests on these points:

• The 35% figure is the six majors’ combined share, not Shell’s. Shell’s own listed share is 5%, and Oil Change International’s attributions follow ownership interests; they do not show that Shell sold or shipped the oil.^{6, 40}
• AFSC does not show that Shell oil reaches military or settlement fuel supplies.⁵
• Later Oil Change International updates (November 2025, September 2026) do not name Shell in the pages read.^{18, 19}
• Ravin is a minority, civilian-technology holding that may no longer be held, and no Israeli state use is evidenced.
• The Gaza Marine licence was sold in 2018 as portfolio simplification. Shell’s statement said the deal was “consistent with Shell’s strategy to high-grade and simplify our portfolio”.⁴¹
• The UK and German retail business has been owned by Octopus since December 2023.¹⁰
• No public evidence identified of Shell Energy produce sourcing, settlement-origin goods, Israeli revenue, or physical footprint in Israel.¹³
• No Israeli-nexus floor factor (founding or headquarters in Israel, state ties) applies to any Shell Energy entity.

Named Entities and Evidence Map

Shell plc, Shell Ventures, Shell E&P Italia, BG Great Britain Limited, Palestine Investment Fund, Impello Limited, Octopus Energy, Ravin AI Ltd, RepAir, Bazan, Delek, Paz and Sonol (downstream recipients per AFSC; Delek, Paz and Sonol operate stations including in settlements).^{5, 24} A 2013 report that Shell might sell its Woodside stake over Leviathan was disputed by Shell, which said it had already divested a substantial stake [pre-2020].⁴²

Political: Political

Mechanism of Involvement

Political (I = 2.60, M = 7.00, P = 8.00, V = 2.60) rests on a Double Standard frame, retained at examiner adjudication. Shell publicly exited Gazprom partnerships in February 2022 (“We are shocked by the loss of life in Ukraine, which we deplore”), but declined to comment to BHRRC on Israel-related supply questions that included the ICJ ruling (10 September 2024) and did not reply to Rai 3 (May 2026).^{7, 8, 9} The audits find no general Shell statement on Israel-Palestine in the pages retrieved.

Counter-Arguments and Evidence Limits

• Declining to comment is not an admission, and no court, regulator or OECD action against Shell on Israel-Palestine was identified.
• The Gazprom comparison involves a different kind of event (a state-sanctioned exit amid sanctions) than an NGO inquiry.
• Shell’s lobbying disclosures show energy-market topics, and the page read does not mention Israel.⁴³
• No public evidence identified of donations to settlement groups, FIDF or JNF, of CEO or Chair statements or philanthropy, or of any BDS-style campaign specifically targeting Shell.
• The audits found no listing of Shell in the OHCHR database or A/HRC/59/23 coverage read. This is not exhaustive, as primary documents were not text-searched.^{20, 44}

Named Entities and Evidence Map

Wael Sawan and Sir Andrew Mackenzie (name-based searches found nothing), the Palestine Investment Fund, CC Oil and Gas Ltd (possibly Consolidated Contractors Company; unresolved), Vanguard, BlackRock and Norges Bank (listed holders, not searched on Israel topics).^{39, 15}

Complicity Index Score

Method: V6.6 (vetted).

• V_MAX: 3.22 Avg_OTHERS: 0.87
• BRS Score: 283 Tier: D (Moderate Complicity)

V_MAX is set by Economic, where a moderate-activity-type equity and supply nexus (I = 6.1) is discounted by a low scale (M = 3.8) and moderate proximity (P = 6.8). Political contributes only through Avg_OTHERS. The tier reflects documented but indirect and partly unresolved economic links, with no military or digital nexus. The method is scale-free, evidence-only and human-vetted, and the fixed scores were not altered.

Methodology Note

• Evidence comes only from the four domain audits (Military, Digital, Economic, Political); no outside facts were added.
• Scale-free scoring: Impact reflects activity type, Magnitude reflects scale, and Proximity reflects directness.
• Temporal rule: divested or exited operations (Gaza Marine 2018, Shell Energy Retail 2023) are mitigated and flagged [pre-2020] where applicable.
• Entity attribution: no transitive guilt. Allegations naming Shell plc or upstream units are not attributed to Shell Energy entities without evidence.
• Settlement operations dual-count Economic and Political; none were identified for Shell.
• “No public evidence identified” is used wherever the audits’ checks found nothing. Unverified or unresolved items (stake sizes, Shell-handled cargo, Seasalvia charter, Ravin status) are carried with caveats.