Security Plan

SECURITY PLAN

Reference. Date: Owner : Version: A01

ACTIVITY:

PREPARED BY: Kennedy Ediworo Date: ations,

Date:
Sign: Digitally
Date:
REVIEWED BY:
Date:
AGREED BY: Sign:
Date: HE
APPROVED BY Sign:
01'00'

EFFECTIVE FROM
Revision Date Detail Revision By

R01 Initial review for commencement o A01f activity

Approved for commencement of a

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TABLE OF CONTENT

1.0 INTRODUCTION: ....................................................................................................................................... 1

2.0 THREAT ASSESSMENT: ........................................................................................................................... 2

2.2 Risk Mitigation Plan: ................................................................................................................................... 3

2.3 Communications Plan ................................................................................................................................. 5

2.4 First Aid Plan: ............................................................................................................................................. 5

2.5 SECURITY RECOMMENDATIONS: ........................................................................................................... 6

3.0 ETHICAL AND LEGAL LAW ENFORCEMENT CONDUCT PERSONNEL AT SEPCiN LOCATIONS. ......... 7

3.1 ETHICAL AND LEGAL LAW ENFORCEMENT CONDUCT ......................................................................... 7

4.0 VOLUNTARY PRINCIPLES ON SECURITY AND HUMAN RIGHTS (VPSHR) ............................................ 8

5.0 FOREIGN CORUPT PRACTICES ACT (FCPA) History .............................................................................. 9

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Security Plan

1.0 INTRODUCTION:

Description of task:

Parties involved in task:

contractor, sub-contractor,
GSA, SPDC, local communities,
etc.
Estimated number of
personnel on site:

Location: work site, lay

down yards,
accommodation, etc.
Dates and duration of task

Working days & hours:

Routes to site

Description of site:
Define perimeter, pipeline,
etc.

Tools and type of equipment

on site:
4x4, crane, porta cabins,
storage ISO container,
welder, etc.

Additional relevant info:

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Security Plan

2.0 THREAT ASSESSMENT:

Current threat level for locations relevant to the task/activity:

Severity Rating and Low Medium High Extreme Attractiveness

attractiveness assessment
Criminality H8 Yes
Organized Crime H7 Yes
Activism M5 Yes
Civil/ Community Unrest L1 No
Armed Conflict L1 No
Information Security L1 No
Terrorism L1 No

Threat assessment last reviewed: 02/09/2022

Additional SIS comments relevant to the task/activity:

2.1 OPERATING LEVELS:

This security plan works in conjunction with SPDC’s Security Operating Levels (SOL’s). Additional security is
used to manage the risk at each level. The SOL’s are as follows:

Green – Base line Security Performance Criteria met

Amber – Increased Security measures against Generic threats
Red – Elevated Security measures against specific Threats
Black – Reaction to an attack or Intelligence of an imminent attack
(Further details from Group Security Standards and Security Manuals)

1 2 3 4 5 6 7 8 9 10 11 12

CURRENT SOL as at 7TH September 2022 is – Red

Security Resources:

SN Type of Resource Quantity in relation to Remarks

SOL
1 Military Escort 12 2 OPDS teams + pathfinder for Security cover for Black Zones.
2 Other GSA 8 Lead and Chase Security cover to/fro site daily
3 Patrol vehicle 3 4x4 Hilux
4 Military Patrol Vessels (MPV) 0
5 Community night guard Commence shift at 1700hrs – 0730hrs
6 Portable guard hut 1
7 Patrol Boats

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2.2 Risk Mitigation Plan:

Security Credible Control Measures S Accountable “Actions On” Guideline

O Party
Threat Scenario
L
Cat
• Night watchmen from local • Night watchmen to conduct roving patrol through the
community. evening as a deterrent using flash lights.
• Materials access and controls • In the event night watchmen spot thieves attempting to
Criminality Theft or vandalism system steal materials tools etc, immediately call PSS
of equipment at • Materials, machinery, tools, • PSS call GSA to respond
site equipment etc. left of site • Night watchmen to observe from safe distance and keep
clustered together PSS informed
• Portable giraffe lighting • PSS to notify SOC
• Or GSA securing

Criminality Vandalism of
equipment left at
site

•Obtain & confirm workable MOU & All incidents must be assessed and
LTO/FTO managed individually actions on guideline:
•Use of SIS intelligence • Take necessary steps to deescalate the situation
•Good Community relations’ practices • Consider stopping work and relocating from site
and strategy. • Inform PSS and GSA
Civil unrest Local community •Continuous liaison with Government, • PSS to inform ASA, SOC
invade site Host Communities and Security • ASA to inform ER and Assets
agencies • If possible, secure all tools and materials to help prevent
•Employ local labour where applicable. theft
•Prompt payment of wages/salaries of
community labourers

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• Identify community focal point

•GSA collocated at site
•Regular updates from GSA/PSS on
emerging threats, tactics and
procedures(TTP’s) used by adversaries
•Withdrawing from, or reducing
operations during high-risk periods
Use of SIS intelligence
Criminality Adversary attacks •Staff Security Awareness alerts and
contractor at site briefs.
using small arms •Security Emergency Response Team
fire available
•Daily POB monitoring and record
keeping by Site Sup and DSS.
•Evacuation plan in place and
rehearsed
• DO NOT PROMISE ANYTHING on behalf of SPDC
Before starting work at site a TBT SHALL be conducted
coving actions on a smalls arm fire attack
General guide lines:
• Immediately find the nearest hard cover and go to
ground.
• Call local GSA commander if not collocated.
• Remain in hard cover until gun fire has stopped
• At an opportune moment call: PSS, ASA, SOC, SOM
• PSS to call ASA and SOC
• ASA to call Asset
• Once safe to do so administer lifesaving first aid to
any casualties

•Before journey check movement As part of their journey management contractor SHALL
restrictions confirm all actions on in the event of an incident before
Use of SIS intelligence starting any journey.
•Effective Journey management
•Brief from GSA in the area through
Criminality Ambush on route PSS
to site •Security briefings for new arrivals
•All staff briefed on Threats and
‘Security Reaction Guidelines’ regularly.
•First Aid training for staff

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Any increased threat will require a risk reassessment. Additional security controls maybe required or the
activity could be suspended to manage risk to ALARP.

2.3 Communications Plan: Communication shall be via GSM

2.4 First Aid Plan:

Response

Nearest hospital: SHELL IA Clinic

Assessment of hospital’s Good

capability (tier 1,2,3 facility):
Approximate drive time: 40 Mins

Medical extraction vehicles: Yes

First aid equipment/materials on Yes

site:
Designated First Aiders: Yes

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2.5 SECURITY RECOMMENDATIONS:

o Lead and Chase Escort from Pipeline Security Pool will take work crew to/from site daily
throughout the duration of the project.

o It is the responsibility of the Contract Holder and Contract User to ensure that this security
plan is implemented and complied with.

o CSR to liaise with TL/PSS and latch onto existing GSF deployments at Ebubu for
additional security support if required

o The Contract Holder will ensure CTS must be obtained and tested before deployment to
each location The ASA, Pipeline East will monitor the atmospherics and trigger a review
when there is a significant change to threat parameters or SOL and communicate
accordingly to CH.

o The Site PSS will be responsible to interface with the GSA and the workers in accordance
with the security plan daily.

o PSS will investigate all incidents of unauthorized entry, violence, theft, vandalism, or any
other acts directed against personnel or property. The PSS will report the action taken to
protect against or counteract any incident immediately to the ASAPE

o The GSA will be the main security outfit employed to protect the site and crew throughout
the duration of the activity

o The GSA so deployed will provide 360* protection – inner ring of security support, as
recommended by the GSA Commander, following his “Recce” (Recognizance)
survey/assessment of sites.

o The use of fire arms by the GSA will be in accordance with SPDC’s rule of engagement
as contained in Shell briefing manual handed over to GSAs on deployment to SPDC
Operations.

A COPY OF THIS SECURITY PLAN MUST BE GIVEN TO THE CSR, SENIOR ENGINEER, AND
THE PSS FOR COMPLIANCE. A COPY MUST ALSO BE AVAILABLE AT SITE ALL THROUGH
DURATION OF WORK.

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Security Plan

3.0 ETHICAL AND LEGAL LAW ENFORCEMENT CONDUCT PERSONNEL AT SEPCiN

LOCATIONS.

3.1 ETHICAL AND LEGAL LAW ENFORCEMENT CONDUCT

• Law enforcement officials must at all times perform their duty under law.
• They must respect and safeguard human dignity and uphold the human rights of all persons.
• They may use force only when strictly necessary and to the extent required in the performance of their duty.
• They are forbidden to inflict, instigate or tolerate any act of torture or other cruel, inhuman or degrading
treatment or punishment.
• They have the duty to safeguard the health of those in their custody and to secure medical care whenever
necessary.
• Suspected unlawful and / or unethical behaviour by law enforcement officials requires prompt investigation.
Arrest and Detention
• The absolute prohibition on torture applies equally to all arrested, detained or imprisoned persons.
• Arbitrary arrest, detention or imprisonment is prohibited.
• Detainees may not be forced to testify, to confess guilt or to incriminate others. Maintenance of Public Order
• Firing indiscriminately into a violent crowd is never a legitimate or acceptable method of dispersing it.
• Law enforcement officials must avoid the use of force or, where this is not feasible; limit its use to the
minimum.

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4.0 VOLUNTARY PRINCIPLES ON SECURITY AND HUMAN RIGHTS (VPSHR)

A. Voluntary Principles are:

• set of rules, principles, standards
• formulated, agreed and endorsed by govts, companies, NGOs • To guide companies
• in maintaining law and order, safety and security
• for the overall promotion and protection of HR

B. Voluntary Principles and SCiN

• Shell companies in Nigeria endorse/embrace VPSHR.
• SCiN protects integrity of assets – personnel, property, and information.
• SCiN advocates respect for people, local community, and environment.
• SCiN observes all laws, local, international laws.
• SCiN formulates and implements policies, procedures and monitors strict compliance.

• SCiN reports and encourages reporting of HR abuses and incidents.

• SCiN aligns with competitors, multilateral companies in information sharing.

C. Principles and You

• You must be guided by principles while within location or performing company operations.
• Bound if under a contract of service for SCiN.
• Your actions could affect image, reputation of SCiN.
• Monitor and supervise compliance.
• Promptly report any abuses you become aware of, Inaction may lead to vicarious liability.
• Avoid actions that could constitute abuse of HR.

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5.0 FOREIGN CORUPT PRACTICES ACT (FCPA) History

• FCPA was enacted by US Congress in 1977.

• Outcome of a1970’s investigations of US Securities and Exchange Commission of 400 US companies.
• Amended in 1998 by the International Anti-Bribery Act of 1998 to implement the anti-bribery
conventions of the Organization for Economic Cooperation and Development (OECD).

The Policy
• The U.S. Foreign Corrupt Practices Act of 1977 ("FCPA") generally prohibits
• U.S. companies and citizens, its subsidiaries, affiliates, directors, officers, shareholders, employees,
representatives and agents worldwide and Foreign companies listed on a U.S. stock exchange, or any
person acting while in the United States, from corruptly (illegal payments, bribes, kickbacks, or other
questionable inducements) paying or offering to pay, directly or indirectly, money or anything of value to a
foreign official to obtain or retain business.
• The FCPA prohibits any US individual or business, employees, representatives and agents from
engaging in the following: Bribes
• Giving or offering to give any money, gift, or thing of value to any foreign official to obtain or retain
business. Third-Party Payments
• Giving or offering to give any money, gift, or thing of value to a third party when there is knowledge that it will
be offered to a foreign official to obtain or retain business.
Political Contributions
• Making contributions to political parties or official to obtain their support for executive, legislative,
administrative or other action that may be favourable to Agents.
Record Keeping and Accounting
• The FCPA generally prohibits the falsification of books and records and sets forth certain accounting

requirements. Legal Payments

• Performance of a contract with a foreign government.

• Processing government papers, (visas, Work Orders, Police protection, mail services, phone services,
power, water supplies, loading and unloading cargo) or actions of a similar nature.
• Providing police protection and inspections of goods
• Providing phone service, power and water supplies, protecting perishable goods from deterioration; or
Actions of a similar nature.
Penalty for Violation
• Penalties for violation of this law are severe:
• FCPA violations can result in significant fines and penalties.
• A company can be criminally fined up to $2 million per violation of the Anti-bribery provisions.
• Culpable individuals can be subject to a criminal fine of up to $250,000 per violation;
• As well as imprisonment for up to five years.

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Security Plan

THE SHELL PETROLEUM DEVELOPMENT COMPANY OF NIGERIA LIMITED

INDUCTION BRIEFING TO GOVERNMENT SECURITY PERSONNEL DEPLOYED TO PROVIDE SECURITY COVER AT
SEPCiN LOCATIONS

DIVISION………………………………....
ASSET TEAM…………………………….
FIELD LOCATON……………………….
BRIEFING TYPE (Tick appropriate box) INITIAL BRIEFING CREWCHANGE BRIEFING

I certify that I have been briefed and understand the SPDC guidelines on the following topics, and my role in upholding the
tenets of the guidelines.

• Human Rights (VPSHR).

• Rules of Engagement and Use of Force
• Health, Safety, Security and Environment
Serial Name Unit Date Signature
No.

Induction Conducted by:

ASAPE/ PSS Name………………………………….

Sign………………………...…………
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SECURITY RISK ASSESSMENT MATRIX

Increasing Likelihood
Consequences

A B C D E

Adversarial Threats

Very Low Low Medium High Very High

Adversarial Adversarial Adversarial Adversarial Adversarial
threat threat threat threat threat

Non - Adversarial Threats

Never heard Heard of in Has happened Has happened Has happened

of in the the industry in the at the location more than once
industry organisation or more that per year at the
or more than once per year location
once per year in the
organisation
in the industry

0 No No No
Injury Damage Impact

1 Slight Slight Slight

Injury Damage Impact

2 Minor Minor Minor

Injury Damage Impact

3 Major Moderat Moderat

Injury e e Impact
Damage

4 PTD or Major Major

up to 3 Damage Impact
Fatalities

5 More Extensive Massive

than 3 Damage impact
fatalities
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