Bullying Business Ethics Geo-services harassment Human Resources marine seismic Marine Seismic Market Marine Seismic Operations mobbing UN Global Compact Whistleblower

Watson Farley & Williams Profits from Corruption and Human Rights Abuses

This website and all the publications it hosts, along with website SeismicRiskManagement,com and Pinterest exists because those mentioned within the posts are criminals who want to continue to lie to their investors, competitors. and even their employees. Confidentiality contracts, such as the one SDK signed with PGS ASA, are intended to prohibit disparaging publications. Corrupt lawyer Rune Olav Pedersen, PGS ASA President and CEO, obviously has no integrity nor competence in honoring legal contracts. The exception to prohibitions in publishing disparaging content is whistleblowing. PGS ASA and its co-conspirators, pervert the course of justice by NOT abiding by their contract terms. They allow the reputation and value of their enterprise to be diminished so that evil and corrupt incompetent management and staff can remain in place. It is obscene. Decent and honest professionals should not do business with these corrupt companies that distort the free market and empower the dishonest and evil to shape the industry for their benefit.

The London Employment Law Racket – Part 3

The Watson Farley & Williams racket is to make illegal behavior appear legal – for the right price! Only corrupt moneyed corporations have such money to spend to illegally retaliate against whistleblowers. Corrupt actors misappropriate and steal resources from shareholders, deceive stakeholders, and preserve an incompetent power structure incapable of competing in a fair market. They do everything professional organizations define as unprofessional and unethical.

Data Protection Act 2018

148 Destroying or falsifying information and documents etc.

(1)This section applies where a person—
(a)has been given an information notice requiring the person to provide the Commissioner with information, or
(b)has been given an assessment notice requiring the person to direct the Commissioner to a document, equipment or other material or to assist the Commissioner to view information.
(2)It is an offence for the person—
(a)to destroy or otherwise dispose of, conceal, block or (where relevant) falsify all or part of the information, document, equipment or material, or
(b)to cause or permit the destruction, disposal, concealment, blocking or (where relevant) falsification of all or part of the information, document, equipment or material,
with the intention of preventing the Commissioner from viewing, or being provided with or directed to, all or part of the information, document, equipment or material.
(3)It is a defence for a person charged with an offence under subsection (2) to prove that the destruction, disposal, concealment, blocking or falsification would have occurred in the absence of the person being given the notice.

Corrupt actors cede power that they are not entitled to and protect co-conspirators and facilitators of non-compliant and criminal acts through bribery, embezzlement and money laundering schemes paid for “legal” advice intended to manipulate and obstruct due process.

This definition crystallizes most of the elements of bullying; the frequency of the bullying, the evolving bullying process and the negativity which results. But it does not reference the power imbalance between the bully and the one bullied; nor does it reference those who observe the bullying but do not intervene; the bystanders. For, as every whistleblower knows, it is the bystanders who underwrite bullying.

The Invisible Hand: When the Firm Becomes the Bully


Bullying Business Ethics Geo-services harassment Human Resources marine seismic Marine Seismic Market Marine Seismic Operations mobbing UN Global Compact Uncategorized Whistleblower Workplace Bullying, Harassment & Mobbing

A Texan’s Run-in with Criminals in Weybridge, England (Republish)

Text first published 4 January 2018. Publication was referenced within PGS ASA sponsored criminal defamation claim against SDK by Thai Legal firm Duensing – Kippen. PGS ASA never claimed a breach in Confidentiality terms and conditions contained within contracts governed by the laws of England. SDK publications are legally protected public disclosure (whistleblowing). PGS ASA sponsored claims are illegal retaliation.

Texas has yet to learn submission to any oppression, come from what source it may.

~ Sam Houston

Well when you’re down on your luck and you ain’t got a buck in London you’re a goner.

~ Gary P. Nunn, London Homesick Blues

I lived and worked in Weybridge, England with my wife and two children from 26 September 2010 until 24 December 2013.  I am a USA citizen and was sponsored to work with PGS Exploration (UK) Limited, 4 The Heights, Brooklands, Weybridge, KT13 0NY (PGSUK), on a Tier 2 visa.  I left Weybridge and my employment after being gang-bullied.  I am now certain that I was also a target in a confidence fraud game involving my former employer, their contracted legal firm, as well the legal advisor whom I engaged.  My Weybridge story is about a foreign worker who blew the whistle on executive non-compliance and corruption.  I mostly wanted the harassment and bullying to end.  At its core, this is a story about lies and betrayal in the workplace.  It is a tragic tale about how easily co-workers will support, directly and indirectly, those with corrupt authoritative power.  The herein mentioned professionals are trained and experienced and knew full well that their actions were evil, non-compliant, and illegal.  Yet, certain employees were allowed to make the collective decision to bypass their company policies and national laws to aid and abet in crimes against a former colleague.  These individuals conspired to carry out actions that they knew would cause me, and also my family, physical, psychological, financial, and professional damage.  They decided to solve the executive corruption problem through bribes, forgeries, and fraud.  They have continued to pervert the course of justice through silence.  A self-entitled corporate executive class has positioned themselves above the law.  They spend other people’s money to protect and promote agents in their syndicate from responsibility.  This must stop and there needs to be a police investigation, accountability, and justice.  Weybridge, and surrounding communities, benefit when all know that no one is above the law.

The first lesson that targets of bullying (and gang-bullying) need to understand is that the human resources (HR) entity within organizations which publishes and distributes company policies and procedures is part of the enterprise hierarchical power structure and not above it.  In other words, if there is corruption and non-compliance, HR is usually an enabler because of their placement and authoritative power within the organization hierarchy.  It is part of the calculus which toxic management understands.  This is why too often targets of bullying find no relief, and often bring more harm to themselves, if they complain about harassment and bullying through HR.  HR is weaponized to protect those in the upper echelons of an organization and not to police them.  In well managed and compliant organizations, HR will follow policy and behave compliantly because top management demands it.  However, harassment and bullying generally do not proliferate within well-managed and compliant organizations.  Further, there is a substantive argument that harassment and bullying are corrupt behaviors in of themselves which negatively impact most every aspect of enterprise performance.  Beyond this, workplace bullying and harassment is often antecedent to more consequential corruption.  Because the misuse of the HR function is essentially sanctioned, targets of abuse can be robbed of income and then maligned in their industry without resources to fight back against such repugnant practices carried out in corrupt organizations.  Justice can only really come from outside the power structure.

Also, one must understand that when they identify workplace bullies or bullying, they are also implicating weakness in the management practices and power structure.  Enterprise culture permeates from the top-down.  The company directors and top management are ultimately responsible for ensuring legal compliance within the work place.  Directors must take reasonable care to support the health and safety of employees and workplace bullying and harassment are identified as significant workplace hazards.  Directors can be held responsible for data protection breaches, defamation, libel and providing misleading information.  The company secretary shares additional responsibilities with the directors (UK Companies Act 2006). If a secretary fails to ensure that the directors are acting properly in the conduct of the business, they could be held personally responsible.  Further, the company secretary can also be subject to criminal proceedings if company funds are misappropriated.  PGSUK is an affiliate of Norwegian based Petroleum Geo-Services ASA (PGS).  The directors of PGSUK are executives of PGS who reside in Norway.  The PGSUK secretaries are UK residents.   Understanding the authoritative power structure in an organization is beneficial when confronting bullying and harassment in the workplace. 

Corruption is like a ball of snow, once it’s set a rolling it must increase. Charles

~ Caleb Colton

The disappearance of a sense of responsibility is the most far-reaching consequence of submission to authority.

~ Stanley Milgram

My employment with PGSUK terminated upon my signing a settlement agreement contract.  Such a settlement agreement contract is a legal instrument supported by HR records.  Settlement agreement contracts are very binding and require those offered such contracts to enlist legal advisors.  However, in October 2014, months after having left England, citing the UK Data Protection Act 1998 (SAR), I submitted a subject access request (SAR) to my former employer, PGSUK.  What I discovered was that false instruments supporting a false narrative resided within my personnel file.  These were not disagreements of opinion, but documents citing events that never occurred and excluding events which did.  This is a DPA violation.  I was told that the PGSUK data processors (in HR) who were: David Nicholson, PGSUK HR Manager; Laura Haswell, PGSUK HR Staff; Anne Stokle, PGSUK HR Staff; Gareth Jones, HR Staff and Simon Cather, Marine Contract President – Africa.  Nicholson was resolute about retaining these knowingly false – inaccurate – records and to continue processing them and even sent me a threatening letter telling me to stop my interrogatory. 

I also went round-and-round with the Information Commissioner’s Office staff who oversee DPA compliance sharing with them e-mail evidence proving the PGSUK records being processed were false and inaccurate.  The problem was the fact that I separated with a settlement agreement contract which was approved by a legal advisor who should have recognized that the instruments being processed were bogus and inaccurate.  At the time, I did not really understand the depth and cooperation of the conspiracy behind my termination.  I had thought that a spiteful HR manager, David Nicholson, had created these records after my termination.  However, the dates indicated that this data was processed in forming my settlement agreement contract.  The other error I made was that I did not think one’s legal advisor influenced the data being processed so much.  But, in fact, their role is pivotal.  Therefore, my legal advisor had to have been complicit in both creating the false instruments and processing them to affect the terms of the settlement contract.  Because of this, ICO could not challenge the records or investigate PGSUK.  However, this impediment toward truth and justice did not change the fact that the records were illegal.  I had lived the truth and was not going to concede it to corrupt people and practices.

Arriving to the realization that several corrupt and corrupted individuals were involved in executing my settlement agreement contract supported by knowingly non-compliant illegal records in many ways clarified past events.  I did not arrive to my current understanding of events quickly.  I have ventured in one-step at a time.  I have been publicly exposing PGS/PGSUK corruption since my blog post on LinkedIn™, 3 July 2015, An American, the UK Data Protection Act, Petroleum Geo-Services (PGS) and the Tyranny of “Accurate Data” (3-Jul-2015).  In the 20 September 2015, Petroleum Geo-Services (PGS) CEO Jon Erik Reinhardsen Should Resign 2 (20-Sep-2015), evidence is shared to show that the contents held within my personnel file is not accurate.  On 24 May 2016 I published, The Petroleum Geo-Services (PGS) Ambush Meeting and the Definition of Fraud (24-May-2016), following my contact with PGS compliance hotline, Rune Olav Pedersen, PGS General Counsel and Terje Bjølseth, SVP HR.  My request has been simple: authenticate the records held within my personnel file.  Similarly, I recently published correspondence between myself and my legal advisor (team), Philip Landau and Holly Rushton, in the blog post, The Crimes of @PhilipLandau #London #EmploymentLaw #Solicitor and Petroleum Geo-Services #PGS #CEO #Pedersen (30-Dec-2017).  Landau and Rushton, my legal advisors, will not explain how forged documents were used to process the settlement contract agreement which they advised on.  It is clear that there is a conspiracy and cover-up here.  Links to additional blog articles can be reached at, [ was stolen and illegally destroyed through PGS ASA sponsored litigation in Thailand, December 2018. Content moved/re-published to]

If you prosecute a CEO or other senior executive and send him or her to jail for committing a crime, the deterrent effect in my view vastly outweighs even the best compliance program you can put in place.

~ Jed S. Rakoff

Psychopaths are social predators, and like all predators, they are looking for feeding grounds. Wherever you get power, prestige and money, you will find them.

~ Robert D. Hare

Through the period of writing my blog articles responses (silence) from those whom I have exposed have been gauged.  During this time, I have developed a better understanding of what took place.  I know that the final outcome was illegal (forged documents).  Therefore, stepping back and rethinking the events which preceded the settlement contract agreement being proffered in the first place needs to be explored.  The reason that the outcome needed to be illegally altered must be a product of why the settlement agreement contract was proffered in the first place.  I had submitted a formal workplace grievance implicating three principals, my boss, Edward von Abendorff, VP Contract Sales – Africa, his boss, Simon Cather, President Marine Contract – Africa, and David Nicholson, HR Manager, in non-compliant workplace practices that transgressed PGSUK policy and UK employment law.  These actions included defamatory – untrue and harmful – statements and documents intended to impugn and damage me professionally and personally.  Central to this grievance was the abuse of position and misuse of the internal performance management system to demote and terminate me from employment. 

My grievance was researched and confronted these false claims which aligned to tactics used in workplace gang-bullying.  My grievance cited events and data from the work group, referenced PGSUK policy handbook, UK employment law, and literature to demonstrate that I was being harassed and bullied in the workplace.  I believed that PGSUK was in breach of contract in PGSUKs duty of care responsibility in creating a hostile and health-harming workplace environment (health and safety), as well as breach of trust and confidence because principals were departing from policy on multiple levels.  The submission of a formal grievance was prompted by two key events.  The first event was an ambush meeting.  Following this meeting, I requested minutes of the meeting, how the meeting aligned with policy, and informed Nicholson that I wanted to file a grievance.  I was denied all of these requests.  I needed something in writing.  Eventually, Nicholson prepared a letter which covered main points of the ambush meeting.  However, instead of responding to me initial queries, Nicholson added a subject line, Investigation into possible implementation of a performance improvement plan (PIP).

Within the ambush letter, a meeting to discuss the highlighted points was scheduled for 11 September 2013.  This is a very important date in the chain of events leading to my eventual termination from employment.  Mainly, it is important to note that the 11 September 2013 meeting never occurred.  It was rescheduled for 20 September 2013.  Also important to note is that the majority of actions and behaviors referenced within my formal grievance predated 11 September 2013.  The ambush meeting happened in June 2013, and the ambush letter was delivered in July.  In between those two dates, PGSUK had submitted documentation to renew my Tier 2 visa.  This is another key point.  Both the ambush meeting and ambush letter presented defamatory and denigrating content impugning my job performance.  Essentially, I was being told that I was incompetent.  However, these sentiments were not presented to UK Border Agency, an official UK government agency which issued my Tier 2 visa based on the professional shortage occupation list requested by PGSUK so that I could continue working in Weybridge.  This is why I noted that Candida Pinto resigned as PGSUK secretary 13 September 2013 and Carl Richards, PGSUK Head of Legal took over in that role.  So, who would be responsible for the PGSUK actions pre-dating 13 September 2013 in terms of complying with PGSUK policy and UK law?  I never received any content regarding an investigation into implementing a PIP.  I responded to this ambush letter in the form of my written grievance, 20 September 2013.  However, lying to UK Border Agency as a means to employ someone on false pretenses is not appropriate and can be illegal.

Most of the evil of the world comes about not out of evil motives, but somebody saying ‘get with the program, be a team player;’ this is what we saw at Enron, this is what we saw in the Nixon administration with their scandal.

~ Philip Zimbardo

Good manners are cost effective. They not only increase the quality of life in the workplace, they contribute to employee morale, embellish the company image, and play a major role in generating profit.

~ Letitia Baldrige

The objective of gang-bullying is to oust the target from employment.  Had I endured such workplace conditions in the USA, I likely would have quit and moved on sooner and not raised a grievance.  The grievance cited my nationality as factor elevating the abusive workplace bullying behaviors to be harassment.    My family was in a foreign country on visas sponsored by PGSUK so that I could work in their offices.  It would not have been easy or cheap – or even legal – to just quit and leave.  I was working on an employment contract.  All parties had invested a lot for my family to be living in Weybridge.  My Thai wife did not really like Weybridge weather, but did enjoy trips into London and also found a spiritual community at the Thai Buddhist temple in Wimbledon.  Our family would take trips to Wimbledon several weekends while living in England.  My children attended Manby Lodge and then moved to Saint James C of E primary school.  The teachers and administration were professional, attentive and caring to our daughters.  I was very grateful of this.  We all enjoyed taking the train and seeing the sites in England that we journeyed to from Weybridge.  So, my children especially have fond memories of our time living in Weybridge.  I want to make it clear that it was a few bad apples within my workplace which displaced my fonder memories of living in England.  Unfortunately, however, it was not only PGSUK professionals who behaved corruptly.  PGSUK influence through misappropriated resources and lies infected others, as well. 

On 20 September 2013, I delivered my formal grievance personally and through e-mail.  The attendees of that meeting were me, my requested co-worker witness, John Barnard, Abendorff, and the meeting host, Nicholson.  These individuals also were sent a copy by e-mail, as were Cather, his boss, Per Arild Reksnes, EVP Marine Contract; Terje Bjøseth, SVP HR, who Nicholson reported to, and John Greenway, SVP Marine Contract.  Greenway often attended our groups planning and strategy meetings via phone conference from Lysaker, Norway and so I thought his impression and comments would be important and useful.  Barnard had been privy to the several e-mails regarding the original 11 September 2013 meeting and rescheduling, as well.  Barnard was the only one beyond me, and the principal three cited in the grievance, that was in the loop.  I recall Abendorff’s surprise when he first read the grievance and learned that Nicholson and Cather were also named.  I think that the three had prepared for me to complain about only Abendorff.  This would have allowed them to contain and control things even easier.  Now, Norway executives were brought into the resolving the matter. 

A grievance hearing meeting was scheduled for 14 October 2014, a Monday.  On 10 October 2014, Nicholson called me down to his office and offered me a settlement contract agreement to end my employment with PGSUK and forego the grievance hearing.  I rejected the offer.  However, I was made aware that I would require a legal advisor if I did accept a settlement agreement offer to end my employment.  I was reading and came upon an article by Philip Landau and completed an online query prior to 14 October 2014.  I have written about my initial encounter with Landau within the recent blog article, The Crimes of @PhilipLandau #London #EmploymentLaw #Solicitor and Petroleum Geo-Services #PGS #CEO #Pedersen (30-Dec-2017).  Within this article e-mail communications between Landau and his associate, Holly Rushton, and I are shared to show that Landau had been provided with accurate information that contradicts the contents held within my personnel file.  Therefore, I have concluded that Landau and Rushton were not my advocates, but rather were compromised and knowingly forwarded forged documents to advance an illegal settlement contract agreement.  This settlement contract benefited the corrupt interests of the named bullies, as well as the directors/secretary of PGSUK.  These actions allowed corrupt PGSUK agents to escape accountability for overseeing a health harming workplace and breaching several PGSUK policies and even UK employment laws.  Further, PGSUK also enlisted the services of Watson, Farley, & Williams, employment solicitor, Rhodri Thomas, to help facilitate this confidence fraud. 

The trouble with lying and deceiving is that their efficiency depends entirely upon a clear notion of the truth that the liar and deceiver wishes to hide.

~ Hannah Arendt

In any society, fanatics who hate don’t hate only me – they hate you, too. They hate everybody.

~ Elie Wiesel

The creation and processing of forged / false instruments required that usual steps of due diligence and prescribed processing procedures were intentionally neglected.  None of the relevant documents were countersigned by me.  Many were not signed at all.  None of the relevant documents were signed by my boss, Abendorff.  There were no supporting documents to back-up the content.  Mostly, it seems they were authored by Nicholson.  These documents would probably not reach a legal standard for use in a court of law, which is the standard for HR records.  Stokle had arranged the appointments between me and the occupational health nurse, which happened while the negotiations were underway.  However, the generated final report was kept from me and was also not preserved within my personnel files.  Haswell and Jones were discussing moving arrangements for me to move back to the USA while the negotiations were in progress.  Similarly, Thomas, of Watson, Farley and Williams, did not check with individual’s who had processed my Tier 2 visa and note the performance based settlement did not coincide with a SOL Tier 2 visa requirement.  Landau and Rushton did not even address my many queries on these topics.   Everyone except me was seasoned and knowledgeable of the legal standards for legitimate personnel actions, but they instead followed the criminal lead.  And this is why I was their target in the confidence fraud game.  

Substantial weight is placed on my signing the settlement agreement contract.  However, my signing the settlement agreement is a product of multiple misrepresentations and the withholding of information.  There was a calculated effort to defraud me that all of the fore mentioned legal and HR “professionals” fully understood.   Further, my assignment was in contract sales, and so those above me in the hierarchy understood the law of contract.  Everyone who was directly involved in my ordeal knew exactly what they were doing was immoral and illegal.  Now, they all have a vested interest in maintaining the false narrative.  In one of my more recent blog articles, Petroleum Geo-Services #PGS #CEO #Pedersen and the Management of Gang Rape (28-Oct-2017), I liken these events to being the victim of gang-violence, where the guilt of everyone is known, but the rapists cooperate to keep the truth hidden.  The impact of workplace mobbing on targets is documented to be devastating on multiple levels.  The health harming aspects of workplace bullying was a point emphasized within my grievance document, which by the way, is also not preserved within my personnel record file.  This is without the extra seasoning of crimes perpetrated on a target already dealing with living in a foreign country.  What PGSUK/PGS corrupt agents have done is not inconsequential.  The silence hides the seriousness of their crimes.  What PGS/PGSUK constructed was a completely false claim to replace a more serious claim where directors and executives would be held accountable.  Since my termination, many of the key actors have been promoted.  No negative repercussions, beyond my blog post articles, for their robbery and assault of me and my family. 

In a legal organization, thorough investigations would be carried out to determine if best practices, internal policies, and local laws were adhered to in forming a conclusion.  At PGS/PGSUK no investigations and bogus conclusions are composed to form a false narrative.  In a legal organization employees who departed from such practices demanded in their professional capacities would be reprimanded and possibly disciplined.  Many of the described corrupt actions could warrant summary dismissal.  That is not how things work at PGS/PGSUK.  Within this organization, such violations are rewarded.  Be a crooked general counsel lawyer overseeing legal compliance and screw up a simple settlement contract agreement and one can expect to become CEO!  Others may be lauded within the Company’s responsibility report.  Others will receive promotions and likely stellar recommendations so they may further their careers.  Honest whistle blowers will have their careers halted and be blacklisted robbing them of income and opportunity. This is not the way it is supposed to work.  Maybe many in the communities around Weybridge are capable and looking for an opportunity in an HR, legal, geo-science or IT field.  However, the position they seek is filled by a criminal!  Help me in demanding a full external investigation of PGSUK.  It will improve the neighborhood.  If you are or know a legal advisor who can remedy this situation, please e-mail:

Cruelty is all out of ignorance. If you knew what was in store for you, you wouldn’t hurt anybody, because whatever you do comes back much more forceful than you send it out.

~ Willie Nelson

“Truth” in Texas is topic sensitive. If you’re doing a business deal, a true Texan always stands by his word. There is nothing more sacred to Texans than their word, and they will do anything in their power to meet their obligations. But when it comes to tellin’ stories, the whole truth thing blurs quite a bit.

~ Jim Gramon
Petroleum Geo-Services (PGS) CEO Jon Erik Reinhardsen Should Resign (6-Sep-2015)


Bullying Business Ethics Geo-services harassment Human Resources marine seismic Marine Seismic Market Marine Seismic Operations mobbing UN Global Compact Uncategorized Whistleblower Workplace Bullying, Harassment & Mobbing

Watson Farley & Williams’ Neeta Aulak

The London Employment Law Racket – Part 2

PGS ASA CEO & President, as well as former PGS ASA General Counsel, Rune Olav Pedersen, does not consider any of the several images and blog articles posted online since 3 July 2015 disparaging or a breach of the Confidentiality terms and conditions of PGS ASA employment contracts GOVERNED BY THE LAWS of ENGLAND. PGS ASA enlists Global legal firm Watson Farley & Williams to advise them on their employment contracts. Both PGS ASA and Watson Farley & Williams QUIETLY LOVE THESE PUBLICATIONS. How else could they remain published?

HR Is Not Your Friend. Before You Complain At Work, Watch This…

Neeta Aulak is a disgrace to the legal profession and should be investigated for multiple crimes. This employment law racket hurts the honest hard working professional and protects the corrupt and evil corporate elite and their minions. Aulak has a contract that allows her to sue the author, SDK. The problem is that the contract is fraudulent, just like Neeta Aulak “compliance.”

In London, employee’s who are proffered a settlement contract to end their employment are required to seek the advice of a solicitor/lawyer.

This requirement for solicitor advice to accept a settlement offer makes termination by settlement contract an inside game for lawyers. Corporations obviously have an advantage of the purse. Unscrupulous lawyers/solicitors will put on their show understanding always where the money comes from. The most lucrative market is to favor the party that controls the money. This is the racket. It is the perfect recipe for bribery, fraud, and embezzlement to intimidate the hapless employee into accepting terms and conditions that favor the corrupt moneyed corporation. Law firms protect corrupt management and dispose of harassed and abused employees through manipulating the fair and legal processes and raking-in the cash. Corrupt global law firm Watson Farley & Williams is at the pinnacle of this corruption.

This website can only exists because Watson Farley & Williams got caught. Still, Watson Farley & Williams continue to pervert the course of justice and lie with impunity due to a dysfunctional compliance and police system that seems impotent against white collar corporate crime. Watson Farley & Williams’ fraudulent contracts with their confidentiality terms and conditions are never invoked because all lawyers involved know these instruments are to intimidate the abused into silence. They are worthless in a just court room. Neeta Aulak knows this better than most lawyers of “compliance.”


Bullying Business Ethics Geo-services harassment Human Resources marine seismic Marine Seismic Market Marine Seismic Operations mobbing UN Global Compact Uncategorized Whistleblower Workplace Bullying, Harassment & Mobbing

Rhodri Thomas and the London Employment Law Racket that Helps Corrupt Corporations Destroy Whistleblowers

Ask Rhodri Thomas how unscrupulous Employment Law Firms help corrupt corporations harass, defame, defraud and destroy abused employee whistleblowers and their families with the help of the corrupt Global Employment Law Racket

Settlement Agreements may be offered in many situations, whether during or after employment. They may, for example, be used to avoid a drawn-out performancedisciplinary or redundancy process, which can often be costly and time-consuming for an employer and lead to ongoing contention with the employee.

– Landau Law Solicitors website


Bullying Business Ethics Geo-services harassment Human Resources marine seismic Marine Seismic Market Marine Seismic Operations mobbing UN Global Compact Uncategorized Whistleblower Workplace Bullying, Harassment & Mobbing

PGS ASA: Q1 2021 Update Disinformation

View the autosave


Bullying Business Ethics Geo-services harassment Human Resources marine seismic Marine Seismic Market Marine Seismic Operations mobbing UN Global Compact Uncategorized Whistleblower Workplace Bullying, Harassment & Mobbing

PGS ASA 22 April 2021 Audiocast Q1 2021 Results – What to Expect

PGS ASA Continually Lies to its Stakeholders

PGS ASA Board of Directors and Executive Management are Criminally Negligent. PGS ASA Board of Directors and Executive Management are so Corrupt that they do not even attempt to Counter such Allegations through the use of Contracts Containing Confidentiality Terms and Conditions.

Cowardly PGS ASA Board of Directors and Executive Management will allow the reputations and value of companies associated with the agents of the criminal conspiracy to be damaged rather than address allegations of their corruption.


Bullying Business Ethics Geo-services harassment Human Resources marine seismic Marine Seismic Market Marine Seismic Operations mobbing UN Global Compact Uncategorized Whistleblower Workplace Bullying, Harassment & Mobbing

Regarding Accused Criminal DTN General Counsel Ben Kelly

Open Letter to London DTN Executive Team Requesting that General Counsel Ben Kelly Employment be Terminated

Negligent hiring claims are made when an injured party believes an employer should have known about an employee’s criminal or dangerous background. An employer can be held liable if its employees inflict harm on a third party when the employer should have discovered that risk through a reasonable background check.

What Are Negligent Hiring Claims?

pgs asa ben kelly

watson farley williams ben kelly

dtn ben kelly general counsel

from:Steven Kalavity <>,,,,,,,,,,,,,,,,,,,,,,,,,
ActionFraud <>,
Alan Zeffertt <>,
Andrew Weir <>,
Carl Richards <>,
GDPR <>,
Holly Rushton <>,
ICO Case-Work <>,
Investor Relations – 01 Telenor <>,
Investor Relations – 02 Telenor <>,
Investor Relations Equinor <>,
John Francas <>,
Landau Law <>,
Law Society UK Complaints <>,
Minister of Transport Norway <>,
Norway – Police <>,
PHSO-01 ICO <>,
PHSO-02 ICO <>,
Rhodri Thomas <>,
Tippaya Moonmanee <>,
USA Consulate – Norway <>,
date:Apr 3, 2021, 12:58 AM
subject:Open Letter to London DTN Executive Team Requesting that General Counsel Ben Kelly Employment be Terminated

4A Time limit for actions for defamation or malicious falsehood.
The time limit under section 2 of this Act shall not apply to an action for—
(a)libel or slander, or
(b)slander of title, slander of goods or other malicious falsehood, but no such action shall be brought after the expiration of one year from the date on which the cause of action accrued

Limitation Act 1980

Contact DTN


Steven D. Kalavity (SDK), former PGS ASA employee and PGS ASA, Watson Farley & Williams, Landau Zeffert & Weir / Landau Law Whistleblower and Confidence Fraud Victim.

Attention DTN Executive Management:

  • John McPherson, Chief Administrative Officer
  • Ben Kelly, General Counsel
  • Marc Chesover, President
  • Tom Dilworth, Chief Financial Officer
  • Lars Ewe, Chief Technology Officer
  • Sarah Stansberry, Chief Marketing Officer
  • Doug Bennett, Chief Product Officer
  • Josh Langford, Chief Revenue Officer
  • Mark Holland, Senior Vice President

As a Marine Contract Sales Supervisor – Africa, I used to work with Carl Richards, [PGS Exploration (UK) Limited] Head of Legal and Company Secretary and his legal staff, at the time, Ben Kelly.  Richards and/or Kelly would review and recommend amendments to contract terms and conditions for marine seismic/EM data acquisition and processing projects.   I was informed that Richards and Kelly had read my written grievance and also recommended that I sign a settlement contract agreement rather than proceed through the grievance process which had illuminated untoward executive behaviors and decisions.  Therefore, Richards and Kelly sanctioned, as well as participated in, all of the processes that resulted in creating these false and inaccurate personal data records affecting my termination under false pretenses. 

Carl Richards, Arbitrary and Capricious Company Secretary, PGS Exploration (UK) Limited ( 24 February 2018)

DTN General Counsel, Ben Kelly, is an international criminal. Kelly has never denied these accusations, even though he is legally and contractually obligated to do so. Failure to disclose is a form of fraud that perverts the course of justice. Kelly is involved in both of these crimes, as well as others, but has never been arrested, charged and tried for his crimes. Unfortunately, this speaks more to the dysfunction of the police who perform astonishingly poorly in matters of white collar crime, especially in the United Kingdom. Another reason is that companies such as DTN are negligent in their hiring process and do not practice a thorough due diligence process. DTN should be held accountable for this. Kelly is contractually bound to Confidentiality terms and conditions that prohibit the publication of content by SDK that publicly disparages him. (This public disparagement impacts DTN stakeholders.) The exception to such publications is if they are protected as whistleblowing, as defined by the UK Public Interest Disclosure Act (PIDA). Kelly not invoking the contractual Confidentiality terms and conditions perverts the course of justice and causes substantial harm to the whistleblower and victim of Kelly’s criminal conspiracy where DTN is complicit if it fails to take corrective action.

The global criminal conspiracy that Kelly has played a principal role in has been vile and evil. Kelly’s crimes have been especially abusive to SDKs dependent family members. SDK is a US citizen who was employed by PGS Exploration (UK) Limited, 4 The Heights, Weybridge, England, KT13 0NY. In 2013, Norwegian parent company Petroleum Geo-Services ASA (PGS) had four divisions. SDK was a Sales Supervisor with the Marine Contract Division, Africa Region. SDK interacted with Kelly often enough from when he was a temporary employee borrowed from Watson Farley & Williams through when he was hired full-time by PGS as Legal Counsel. Kelly provided legal and contractual oversight and advice for PGS business in Europe, Africa and the Middle East (EAME). My interactions with Kelly while working in Weybridge were always positive and professional. However, SDK did have issues with his immediate supervisor, Edward von Abendorff. Since SDK was bound by an employment contract requiring PGS sponsorship of a Tier 2 work visa, SDK could not easily extricate himself from the toxic foreign workplace.

SDK did start to search for an escape from Marine Contract Sales – Africa. This apparently infuriated Marine Contract Africa Region President, Simon Cather. Cather and von Abendorff teamed-up with PGS EAME Human Resources Manager, David Nicholson to make SDKs work in Weybridge a living hell. On 13 June 2013, Nicholson invited SDK to an ambush meeting which Cather and von Abendorff also attended. SDK has came to learn some time ago that ambush meetings are a common tactic used by workplace bullies. Following this meeting, SDK emailed Nicholson requesting how the meeting conformed to PGS policy, minutes from the meeting, and how to submit a grievance. Nicholson denied SDK all of these requests. However, on 24 July 2016, Nicholson signed and delivered a letter to SDK on behalf of PGS Exploration (UK) Limited. SDK has referred to this as the ambush letter. The ambush letter became the predicate for SDKs grievance that was delivered to PGS and PGS Exploration (UK) Limited management / agents on 20 September 2013 because the 13 June 2013 meeting minutes were never provided. The illegal mishandling of the 20 September 2013 grievance by PGS has been the impetus to all SDK PGS focused online publications, including this one. PGS has never responded directly to any of SDK online publications. PGS has never invoked a breach in the Confidentiality terms and conditions governed by the laws of England that are contained within the SDK and PGS Exploration (UK) Limited employment contract. Silence is consent if such a breach is not invoked within one-year of publication (The UK Limitation Act 1980 allows one year from publication date to file defamation and malicious falsehood claims).

In September 2018, the criminal mob pursued blackmail / extortion to get SDK to de-publish legally protected (whistleblowing) content from his website, in Thailand. PGS Exploration (UK) Limited is registered with Companies House, which means it operates by the laws of England (and Wales). The last thing that PGS Exploration (UK) Limited wanted to do is make a claim under the English system because the criminal conspiracy and fraud would be obvious. However, through bribing Thai legal firm Duensing – Kippen to deliver false criminal defamation claims while former employee, crime victim and whistleblower was living in Thailand, PGS sought to erase the truth so that they could continue deceiving customers, investors and competitors. About a year ago, Duensing – Kippen continue to threaten SDK after he returned to the USA through delivering claims to the home of SDK Thai relatives to terrorize them. How can PGS have a criminal defamation claim in Thailand under Thai law, but not a breach in the Confidentiality terms and conditions of a contract governed by the laws of England? They can’t. These two realities cannot legally co-exist. And Ben Kelly knows this too, as he allowed SDKs family to be terrorized. Ben Kelly is a cowardly criminal.

DTN must terminate Kelly from his role of General Counsel and investigate. If Kelly has not invoked contractual Confidentiality terms and conditions governed by English law to protect his and the organizations he has agency reputations, Kelly is being allowed to damage DTN reputation and value. It must be assumed that Kelly is perverting the course of justice, which is a crime in of itself. How can DTN justify employing a criminal in executive management to DTN stakeholders? Kelly defamed and defrauded a foreign worker whistleblower. Kelly allowed non-compliant defamatory forged documents to be illegally used to terminate employment and then blacklist SDK from employment in the industry – or any industry that is polluted by the false narrative. Kelly allowed health reports substantiating the health-harming impact of PGS’ toxic workplace to be ignored and destroyed. Kelly contributed to the violent assaults that placed the life and health of the victim of abuse in danger, along with his family. Upon returning to Houston, Texas, unemployed by fraud perpetrated by Kelly, et al., my family suffered. Kelly’s continued silence is abusive and illegal. And Ben Kelly knows it. DTN should also know it. But, this is the warning flag. DTN needs to do the responsible thing for all stakeholders. Protecting and employing a child abusing criminal piece of shit like Ben Kelly is a breach of DTN values.

Regards, SDK

… Gareth Jones, HR Officer; Ben Kelly, Associate Counsel.  Nevertheless, the numbing silence and hiding of corruption continues to proceed unanswered to the collective detriment of PGS and the majority of its honest stakeholders.  The bad publicity compromises PGS company reputation and market value. In addition, the corporate silence compromises my professional reputation by design.

Boycott Petroleum Geo-Services (PGS) Capital Markets (25 July 2016)
This Tweet was sent to @PGSNews and others in 2017. PGS ASA et al. never invoked a breach in the contractual Confidentiality terms and conditions. Lawyer and PGS Exploration (UK) Limited Secretary lied and complained to Twitter to get SDK Twitter accounts restricted. Why would innocent people do this? PGS behaves irresponsibly and silences whistleblowers so they can rob and deceive stakeholders. When will the police wake-up?


Bullying Business Ethics Geo-services harassment Human Resources marine seismic Marine Seismic Market Marine Seismic Operations mobbing UN Global Compact Uncategorized Whistleblower Workplace Bullying, Harassment & Mobbing

Norway’s PGS ASA Bull Shit Governance (BSG) Report 2020

People who invest in PGS ASA or give them their business are stupid and support evil corruption that hurts honest and hard working global citizens and the energy industry.

PGS ASA engaged Thai law firm Duensing – Kippen to blackmail whistleblower SDK who was living in Thailand to de-publish legally protected public disclosure. PGS ASA has misrepresented legal and contractually protected public disclosure (Public Interest Disclosure Act 1998) as CRIMINAL DEFAMATION under Thai law. PGS ASA sponsored vexatious litigation led to the theft of site where whistleblower SDK legally protected content was published from August 2016 – December 2019. PGS ASA and SDK are bound by contracts governed by the laws of ENGLAND. The claim of criminal defamation is absurd. The contracts contain Confidentiality terms and conditions that provide legal avenues of redress for publications that disparage PGS ASA and its stakeholders. Disparagement is a much lower legal threshold than defamation. PGS ASA has never behaved responsibly and investigated whistleblowing claims. Instead of invoking contractual Confidentiality terms and conditions, PGS ASA deletes legally protected disclosure and then lies to content providers (LinkedIn and Twitter) to get whistleblower SDK restricted and his content removed. PGS ASA does not want to respond to whistleblowing claims, but rather wants to continue to be able to deceive and rob PGS ASA stakeholders and the oil and gas industry.

Therefore, any settlement contract that is intended to end an employment relationship on fair, equitable and reasonable terms, yet allows the employer and its agents open to such public ridicule and criticism would not seem to accomplish its intended objectives. 

Petroleum Geo-Services #PGS #CEO #Pedersen and the Management of Gang Rape (24 October 2017) – Republish

PGS ASA should be boycotted and the board and executive management team should be removed and fully investigated. PGS ASA clearly cannot perform optimally until the accusations of board and executive corruption are resolved by a third party police investigation. PGS ASA board and management are behaving very irresponsibly. If PGS ASA board and management are not perverting the course of justice and trying to escape accountability for criminal behavior, then PGS ASA board and management should be removed for utter incompetence. If PGS ASA board and management are not guilty of crimes, then they are imbeciles who cannot manage simple contracts with Confidentiality terms and conditions intended to prevent publications like this one. If lawyer Rune Olav Pedersen is not a criminal, then he is an incompetent buffoon!

Settlement Agreements: The Key Issues for UK Employers

The emotional maturity of a typical narcissistic person is akin to a 5-year-old child who pouts and refuses to play with a friend in the sandbox because the friend wants to share the pail and shovel. The 5-year-old refuses to talk with the friend and angrily storms off to play on the jungle gym with someone else. The bewildered child with the pail and shovel may feel confused, rejected, and may not understand why they can’t share. He or she just wanted to build a sand castle together.

Silent Treatment: Preferred Weapon of People with Narcissism

PGS ASA harassed and abused me and my family in violation of UK Health and Safety Act 1974. PGS ASA discriminated against a foreign worker in violation of the Equality Act 2010. PGS ASA had a DUTY OF CARE responsibility. Instead of following policy and ending the health-harming behavior of a foreign worker, PGS ASA obstructed the worker from filing a complaint and then when a complaint was filed, PGS ASA did not follow their legal and contractual obligations. Instead, they bribed lawyers to form a fraudulent settlement agreement to terminate a whistleblower under false pretenses. PGS ASA created forged and defamatory documents to support their illegal termination of a whistleblower. PGS ASA breached the employment contract violating multiple clauses from Data Protection Act 1998 protections to the Public Interest Disclosure Act 1998 protecting whistleblowers. PGS ASA also defrauded the immigration agencies of the UK, USA and Thailand. PGS ASA denied a foreign worker legal due process afforded to UK citizens through bribery and fraud. The victim of crimes was sent back to the USA through the use of forged documents and a fraudulent contract. Once in the USA, PGS ASA illegally shared defamatory information to blacklist their victim of harassment and discrimination.

Narcissists and the Silent Treatment
TUC Bullying at Work

PGS ASA CEO Rune Olav Pedersen has never denied accusations and therefore confesses that he is a cowardly lying criminal piece of shit. Rune Olav Pedersen is protected by contractual Confidentiality terms and conditions prohibiting former PGS ASA employees from publishing content that disparages PGS ASA stakeholders. Former PGS ASA General Counsel Rune Olav Pedersen takes NO legal action to protect PGS ASA stakeholders reputation and value? It is Rune Olav Pedersen’s most important responsibility as CEO that he is failing at! Lawyer Rune Olav Pedersen knows that PGS ASA breached the original employment contract. Lawyer Rune Olav Pedersen also knows that the documents supporting the illegally proffered termination contract are defamatory forgeries.

Lawyer Rune Olav Pedersen has been allowed through a corrupt corporate governance system and incompetent police processes that allows fraud claims to soar with no redress for victims to remain fraudulently silent and continue to rob shareholders unabated. Cowardly criminal peice of shit Rune Olav Pedersen is allowed to continue his fraud and deceit of PGS ASA stakeholders and publish rubbish “responsibility reports.” It is a travesty.

When a group of adults are allowed to conspire, coordinate, and engage in workplace mobbing, involving fraud, with the explicit intent of harming and robbing targets of their professional livelihood and reputation, it should resonate with all stakeholders.  Such violent plunder and theft is intended to harm and destroy the targets of abuse while protecting the “rapists.”

Petroleum Geo-Services #PGS #CEO #Pedersen and the Management of Gang Rape (24 October 2017) – Republish

PGS ASA was very cognizant that I was a foreign worker and they exploited the condition. The claim of discrimination was grounded in my Tier 2 foreign worker status. PGS ASAs objective was to force me to leave the UK so that the discrimination and harassment claims would not make it to tribunal. PGS ASA also knew that this pressure was exacerbated because I was in the UK with my dependent family members. What I could not foresee was that I was working amid criminals and not civil professionals. My witness in the grievance process, John Barnard, and my legal advisors, Philip Landau and Holly Hobson (Rushton) would accept bribes, betray me, and become co-conspirators in the fraud. Legal firm Watson Farley & Williams’, Rhodri Thomas also accepted bribes to process an illegal termination. I could not foresee PGS ASA lawyers Rune Olav Pedersen, Candida Pinto, Ben Kelly and Carl Richards actually breaking the law to illegally defraud a colleague of money and reputation. Such behavior was beyond my wildest imagination.

If this is not a truthful public disclosure, all mentioned should invoke the contractual Confidentiality terms and conditions. They do not because it is mostly true, excepting specific details. PGS ASA Retaliates against foreign worker whistleblowers. The Norwegian government protects criminals and harassers who embezzle shareholder money to protect their criminal activity. Rune Olav Pedersen should be in prison. People who do business with PGS ASA protect human rights abusers and criminals who distort the free and fair market.

Rune Olav Pedersen (PGS #Pedersen) is responsible for this contract and all of the online postings which it has inspired.  PGS #Pedersen was the principal agent who oversaw the resolution of a grievance addressing workplace bullying/mobbing, harassment, defamation, as well as a litany of other indiscretions, mostly regarding the abuse of position.

Petroleum Geo-Services #PGS #CEO #Pedersen and the Management of Gang Rape (24 October 2017) – Republish

I am an enemy of the corrupt board and management because I wanted them to follow the rules, policies and the law (of Norway and England).  I am an enemy of the corrupt board and management because they have misused company resources, diminished the profession, and deceived customers.  They have sanctioned all this to harm me and my family.  No agent from PGS/PGSUK has publicly challenged my truthful narrative. 

Petroleum Geo-Services #PGS #CEO #Pedersen and the Management of Gang Rape (24 October 2017) – Republish


Bullying Business Ethics Geo-services harassment Human Resources marine seismic Marine Seismic Market Marine Seismic Operations mobbing UN Global Compact Uncategorized Whistleblower Workplace Bullying, Harassment & Mobbing

Open Letter to US Vice President Kamala Harris and Norway Prime Minister Erna Solberg

Equinor – Investigate your Chairman of the Board Nominee (3 June 2019)

RE: 9 March 2021 US Vice President Kamala Harris call with Norway Prime Minister Erna Solberg

Dear White House,

I am a US citizen who is married to a Thai citizen.  We have two daughters and a son who currently hold US-Thai citizenship.

I was employed by a Norwegian company for several years.  My final assignment was with the subsidiary in England.  In England, I became a whistleblower.  My life turned upside-down at that point.  The hardship has very much impacted the health and wellbeing of my two daughters especially, but of course the retaliation has impacted everything connected to me.

I have written the Prime Minister and also published the “Open Letter” online.  I have also written to the previous White House Administration.  I have submitted complaints to the FBI, as well as the UK and Norway police.  A principal perpetrator of the fraud, extortion, defamation, discrimination, and harassment of a US citizen and his US-Thai family is the Chairman of the Board of Norway’s largest company majority owned by the government, Equinor.  

Norway is not a very populated country and it seems that the political and corporate leaders move in the same circles.  Norway has the reputation of being low-corruption.  But, my experience doesn’t confirm this published belief.

As a US citizen, I was denied due process that I was legally and contractually entitled to.  Equinor Chairman of the Board, Jon Erik Reinhardsen oversaw the bribing of my legal counsel to form a settlement contract supported by defamatory forged documents.  

I will publish this letter online, as I have published several other articles.  The settlement contract has Confidentiality terms and conditions which prohibit the publication of content that disparages the company or any of its agents.  I have been publishing accusations of fraud and embezzlement since 2015!  However, no breach is cited because the contract is fraudulent and supported by forged documents.

(to be continued)

RE: 9 March 2021 US Vice President Kamala Harris call with Norway Prime Minister Erna Solberg

continued – part 2

I am not a lawyer.  I am a exploration geophysicist who help oil companies locate oil and gas reserves.  I was working in the business unit focused on Africa projects.  I had on previous assignments worked inside Angola and Nigeria.

I was sponsored by a Tier 2 visa and my wife and daughters (son was not born yet) lived with me in England on dependent visas.  The company did many illegal things to avoid dealing with a grievance claiming workplace harassment and discrimination.  Harassment is horrible anywhere, but this behavior was happening to me in a foreign country.

The main issue is that I was denied due process and false data was used to process the termination that did not coincide with the data used to get my work visa.  So, basically, the company lied to the immigration services of the UK, US and Thailand.  

I have published over 100 complaints.  I have been threatened and even blackmailed with vexatious litigation.  It was corrupt lawyers who agreed to process forged documents to support an illegal contract used to end my employment and blacklist me in the US.  The company shared my data globally, which I have reported to be US mail and wire fraud to the US.  Of course, every penny spent on their harassment of me is embezzlement and theft from shareholders.

I am sad to say that I believe Prime Minister Solberg is party to the obstruction of justice and protection of criminal Jon Erik Reinhardsen.     If the settlement contract is a legal instrument, they could sue me.  As I said, this letter will be published online at

I have been obstructed from the legal process and a fraudulent silence.  It is like being a victim of gang rape, as an article that I published claimed.  I have evidence of several powerful people doing illegal things.  But, I am silenced!  The powerful are not playing by their own rules.

(continued)RE: 9 March 2021 US Vice President Kamala Harris call with Norway Prime Minister Erna Solberg

continued – part 3

The victim – accuser always has to play by the rules.  If they do not, the powerful will exploit any impropriety to its full extent.  The victim – accuser is always under-resourced because the powerful can misdirect resources to make their case.

All I have ever requested is a fair legal process.  But, most of my articles and whistleblowing is simply ignored.  The damage to me and my family is severe, especially for my daughters.  

Professor Freyd out of University of Oregon coined the acronym D.A.R.V.O. which describes the process corrupt actors use to damage accusers.  D = Deny, A = Attack, R = Reverse, V = Victim,  O = Offender.  This strategy is used against female victims of assault by powerful men (usually) in their institutions.  It is also used against whistleblowers.

The families of victims of harassment and discrimination suffer greatly.  If we are serious about helping boys and girls, we need to investigate and remove harassers who violate their obligations in the workplace.  

I believe that investigating Equinor – who lost millions of US dollars in US operations – will reveal many corrupt practices that harm US and Norwegian citizens.  Powerful men (especially) and women must be thoroughly investigated for harassment and discrimination claims.

Please ask the FBI to investigate the Equinor and Telenor board of directors, as well as the directors of PGS ASA.

My family and future demand justice.

Best regards,
Steven Kalavity

Petroleum Geo-Services ASA and the UN Global CON – pact (15-Jul-2018)
Petroleum Geo-Services #PGS #CEO #Pedersen and the Management of Gang Rape (24 October 2017) – Republish


Bullying Business Ethics Geo-services harassment Human Resources marine seismic Marine Seismic Market Marine Seismic Operations mobbing UN Global Compact Uncategorized Whistleblower Workplace Bullying, Harassment & Mobbing

Second Open Letter to the Parliamentary and Health Service Ombudsman

Unlike in unfair dismissal, there is no ceiling on the amount of compensation a tribunal can award for race discrimination. Compensation normally includes an award for injury to feelings and an award to take into account any loss suffered, for example loss of wages or pension. The awards for injury to feelings can vary, however many thousands of pounds is not uncommon. – Race discrimination – Landau Law

Race discrimination – Landau Law

Employers and their legal advisers should not be complicit in using NDAs to cover up allegations of unlawful acts.

UK told to end abuse of ‘gag orders’ in harassment and discrimination cases
UK told to end abuse of ‘gag orders’ in harassment and discrimination cases

This is a second follow-up letter to the 23 February 2021 complaint regarding the Information Commissioner’s Office (ICO) Inability to Protect Data Subject Rights

How can ICO protect data subject rights without robust processes that validate with evidence data controller compliance to GDPR principles?  

ICO Case Reference: IC-44927-G3W4

from:Steven Kalavity <>,,,,,,,,,,,,,,,,,,,,,,,,,
ActionFraud <>,
Alan Zeffertt <>,
Andrew Weir <>,
Carl Richards <>,
GDPR <>,
Holly Rushton <>,
ICO Case-Work <>,
Investor Relations – 01 Telenor <>,
Investor Relations – 02 Telenor <>,
Investor Relations Equinor <>,
John Francas <>,
Landau Law <>,
Law Society UK Complaints <>,
Minister of Transport Norway <>,
Norway – Police <>,
PHSO-01 ICO <>,
PHSO-02 ICO <>,
Rhodri Thomas <>,
Tippaya Moonmanee <>,
USA Consulate – Norway <>
date:Mar 14, 2021, 9:13 PM
subject:PHSO – Complaint ICO IC-44927-G3W4 Follow-Up

Data Controller:  PGS Exploration (UK) Limited, 4 The Heights, Weybridge, Surrey, KT13 0NY

An American, the UK Data Protection Act, Petroleum Geo-Services (PGS) and the Tyranny of “Accurate Data” (3-Jul-2015)

Data Subject:  Steven D. Kalavity (SDK)

The Information Commissioner’s Office (ICO) is the UK’s data protection watchdog charged with enforcing a host of laws that regulate communications, networking and data protection, although the organisation is most renowned for its role in enforcing the EU’s General Data Protection Regulation (GDPR).

ICOs mission is to “uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals”.  The GDPR seven key principles:

  • Lawfulness, fairness and transparency.
  • Purpose limitation.
  • Data minimisation.
  • Accuracy.
  • Storage limitation.
  • Integrity and confidentiality (security)
  • Accountability

Compliance to GDPR Principles is the sole responsibility of the data controller.  When the data controller – data subject relationship is that of employer – employee, data subject complaints of non-compliance to ICO should be considered as protected public disclosure, or whistleblowing.  Under the UK Public Interest Disclosure Act 1998 (PIDA), workers (data subjects in an employer – employee relationship) are to be protected when the public disclosure consists of information where the worker reasonably believes that there has been a criminal offence, breach of a legal obligation, a miscarriage of justice, a danger to the health and safety of any individual, damage to the environment, or the deliberate attempt to conceal any such acts.  

Within the Royal United Services Institute paper, The Silent Threat:  The Impact of Fraud on UK National Security, the concept of a “whole of system” approach in combating the UKs fraud epidemic is discussed:

The wider social and economic impacts of fraud make a clear case for reframing the UK’s fraud problem as a national security priority, for adopting a more centrally led, ‘whole of system’ response and for considerably augmenting the resources within the policing and intelligence community specifically assigned to tackling fraud. Furthermore, to ensure a better understanding of both the fraud threat and the way in which fraud acts as an enabler and vector of other threats, the rebuilding and reframing of the fraud response should not be carried out in isolation, but should build in organisational and informational links to the SOC [Serious and Organised Crime] – and terrorism-specific responses.

Data is multi-dimensional and “lawful and fair use” must be determined on the basis of what domain the data is being used.  Subject data is often shared and processed by multiple organizations.  Data is evidence of compliance or non-compliance to GDPR Principles, fraud or other criminal activity.  Thus, “a whole system” response to curing the global (and UK in particular) fraud epidemic naturally assumes multiple organizations having the ability to identify and then communicate data anomalies, misuse or criminality with other pertinent government and/or private data controllers/organizations.  

ICO needs to be a pivotal player and at the center in this effort.  However, ICOs ineffective one-dimensional approach to data protection does not even protect individual data subject rights, much less detect data misuse or criminal activity amongst government and /or private data controllers with a wide breadth of consequences.  This dysfunction of not being equipped to “connect the dots” exacerbates the fraud crisis because criminals do know how to operate multi-dimensionally.  At the very least, corrupt actors are aware of the fraud epidemic to the extent that any fraud that they perpetrate has little chance of being detected and / or punished.  

In October 2014, data subject SDK submitted a subject access request (SAR) to data controller PGS Exploration (UK) Limited, 4 The Heights, Weybridge, England, KT13 0NY, Companies House Number 02904391.  SDK is a USA citizen who was sponsored for employment in England by PGS Exploration (UK) Limited.  SDK discovered that PGS Exploration (UK) Limited was processing inaccurate non-compliant data (employment records).  ICO did not help data subject SDK rectify the data issues.  In August 2015, SDK submitted his first complaint report to UK ActionFraud (police).  ActionFraud also took no action.  There can be no confirmation of compliance nor justice without ICO or the police demanding that data controllers answer data subject / victim claims thoroughly (with evidence).    

Data subject SDKs experience is that ICO is not fulfilling this mission adequately.  ICO does not compel data controllers to provide evidence to support claims of compliance within data subject access request (SAR) responses.  Even when the data subject provides substantive evidence that the data controllers are in violation of Data Protection Act 1998 (DPA) and/or GDPR principles, ICO takes no action to remedy subject rights abuses.  Data controller PGS Exploration (UK) Limited has been anything but transparent.  PGS Exploration (UK) Limited has never been required to demonstrate their compliance to Data Protection Act 1998 (DPA) or GDPR Principles in a legally verifiable manner.   

Data subject passport information is processed by data controllers as a legal requirement for employing a foreign worker and its lawful use requires the consent of the passport holder.  If the data subject SDK claims is  true that his personal data being processed by PGS Exploration (UK) Limited is fake, this means that PGS Exploration (UK) Limited sponsored visa(s) were cancelled under false pretenses or fraudulently.  Data controller multi-dimensional fair use of subject data must also comport to how foreign subject data is transferred and processed once the data controller – data subject relationship ends within the UK (ICO domain).  PGS Exploration (UK) Limited is misrepresenting multiple national immigration agencies.

PGS Exploration (UK) Limited has been allowed to deliver ridiculous and fraudulent responses to the subject access request (SAR) queries submitted by data subject SDK.  It’s a disgrace.  Further, PGS Exploration (UK) Limited simply does not have the legal right or authority to misuse personal subject data which they do not own nor control.  Specifically, the misuse of foreign worker and dependents passport data is unlawful in many countries, not just in the UK.  PGS Exploration (UK) Limited has used forged / fraudulent subject data to justify the cancellation of visas and remove the victim of crimes as an avenue to legal due process through illegally expelling their victim from the UK and its legal court system..

The GDPR First Principle requires that the data controller process all personal data lawfully, fairly and in a transparent manner. If no lawful basis applies to a data controller processing, subject data processing will be unlawful and in breach of the first principle. Data subjects also have the right to erase personal data which has been processed unlawfully.  Legal data is information related to the law such as court data and attorney data, etc. Organisations from a range of industries benefit from using legal data, such as  business development, legal analytics, case research, and due diligence procedures.

No explanation or clarification is demanded of data controllers by ICO who have very little real knowledge of the subject data accuracy or fairness.  ICO should rely on a data driven standard and fact-based methods to ensure compliance to DPA / GDPR Principles.   Only within the ICO caseworker “legal universe” are documents with no data subject countersignature regarded as “accurate” and “lawful.”  No explanation is required by the data controller, PGS Exploration (UK) Limited.  Such personal data does not meet any legal standard for a court of law.  Thus, by definition it violates GDPR Principles!  

Data subject time-stamped email evidence to relevant parties that prove data controller PGS Exploration (UK) Limited is processing unlawful and inaccurate data is ignored by ICO?  How does this protect data subject rights?  It is also ignored by ActionFraud.  PGS Exploration (UK) Limited refused to remove illegal and inaccurate subject data.  PGS Exploration (UK) Limited was once again allowed by ICO to “rectify” subject data through the inclusion of a complaint email pointing out multiple violations of DPA/GDPR Principles!  The process of rectification should involve the courts and not the unilateral decisions of caseworkers who are not legally qualified or fully informed.  

ICO website: What is the right to rectification?

Under Article 16 of the UK GDPR individuals have the right to have inaccurate personal data rectified. An individual may also be able to have incomplete personal data completed – although this will depend on the purposes for the processing. This may involve providing a supplementary statement to the incomplete data.

This right has close links to the accuracy principle of the UK GDPR (Article 5(1)(d)). However, although you may have already taken steps to ensure that the personal data was accurate when you obtained it, this right imposes a specific obligation to reconsider the accuracy upon request.

What do we need to do?

If you receive a request for rectification you should take reasonable steps to satisfy yourself that the data is accurate and to rectify the data if necessary. You should take into account the arguments and evidence provided by the data subject.

What steps are reasonable will depend, in particular, on the nature of the personal data and what it will be used for. The more important it is that the personal data is accurate, the greater the effort you should put into checking its accuracy and, if necessary, taking steps to rectify it. For example, you should make a greater effort to rectify inaccurate personal data if it is used to make significant decisions that will affect an individual or others, rather than trivial ones.

You may also take into account any steps you have already taken to verify the accuracy of the data prior to the challenge by the data subject.

When is data inaccurate?

The UK GDPR does not give a definition of the term accuracy. However, the Data Protection Act 2018 (DPA 2018) states that personal data is inaccurate if it is incorrect or misleading as to any matter of fact.

What should we do about data that records a mistake?

Determining whether personal data is inaccurate can be more complex if the data refers to a mistake that has subsequently been resolved. It may be possible to argue that the record of the mistake is, in itself, accurate and should be kept. In such circumstances the fact that a mistake was made and the correct information should also be included in the individuals data.

PGS Exploration (UK) Limited escaped third-party legal scrutiny through the ICO decision. ICO did not even ask why inaccurate and unlawful subject data was being processed in the first place?  Data subject SDK believes that ICO allowance of one-sided rectification by PGS Exploration (UK) Limited went outside ICOs legal authority.  ICO permitted PGS Exploration (UK) Limited to avoid the legal system which would have revealed data controller(s) fraud and other crimes.  ICO co-opted a fair path of resolution through allowing  PGS Exploration (UK) Limited ridiculous “rectification” solution which marginalizes the data subject.

ICO should not allow themselves to be intimidated by data controller threats in their defense of subject rights.  ICO should employ thorough interrogatories to be completed by data controller’s that fully address data subject rights.  Data controller’s should not be allowed to threaten data subjects who are lawfully entitled to demand DPA / GDPR compliance and otherwise receive respectful, detailed and legally grounded answers to data subject questions.

ICO has paid little deference to the fact that the data subject was a foreigner and what that meant within the scope of lawful processing of subject data.  There are many requirements that foreigners must meet in order to be legally employed and/or reside within the UK.  Passports belong to the nation that issues them to the data subject.  It is illegal for companies to  employ foreigners who do not meet stringent requirements.  Data controllers must be held accountable for processing subject data such that it meets all of these legal requirements.  

PGS Exploration (UK) Limited provided a nonsensical list of only Human Resources (HR) agents who had processed SDK personal data.  None of the listed HR personnel noted legal issues with processing inaccurate records with no data subject signature?  Apparently, no first line supervisor, lawyer, or anyone involved in forming the termination settlement contract that ended SDKs employment had ever reviewed SDK personnel file contents either.  One of the individuals listed was Gareth Jones.  Gareth Jones is currently the Human Resources Manager for PGS UK.  

In 2014, when SDK submitted his first subject access request (SAR) to PGS Exploration (UK) Limited, Jones resided in Houston, Texas and according to his LinkedIn profile, worked for PGS’ USA subsidiary..  SDK had never worked with nor saw Jones while employed by PGS Exploration (UK) Limited from 2010-2013.  PGS Exploration (UK) Limited stated that HR supervisor Jones processed SDK personal data.  According to the UK Data Protection Act 1998 Eighth Principle (applied in 2014) Subject data must be,

Not transferred to other countries outside the European Enterprise Area (EEA) without adequate protection.

SDK believed that PGS Exploration (UK) Limited violated DPA.  However, PGS Exploration (UK) Limited stated that Jones was an agent/employee of PGS Exploration (UK) Limited and therefore DPA was not violated(!).

ICO demanded no evidence from PGS Exploration (UK) Limited proving that there was no DPA violation and accepted PGS Exploration (UK) Limited explanation.  This practice by ICO demonstrates a one dimensional and myopic view of data that does not protect data subject rights.  This misguided decision had profound consequences.  For one thing, it begs the question was Jones then legally in the USA?  Jones would not be permitted to work in the USA legally without US business sponsorship and employment in the USA, in the same way SDK was allowed to legally work in England.

Data subject rights are not protected when ICO will not confirm data controller compliance.  Afterall, ICO is supposed to be the data protection watchdog.  When ICO does not confirm compliance to DPA / GDPR Principles, data controllers can too easily provide multiple self-serving misrepresentations to escape any accountability.  Without a simple confirmation of the data processor agency, ICO allows violations of DPA / GDPR Principles. However, the practice also facilitates the defrauding of national immigration agencies who actually own and control the subject data being allowed to be processed in a specific limited way by employers.  Foreign passports and visas are subject data under the control of governments and it is often a crime to misuse or misrepresent such subject data.   

Corrupt data controllers who lie pathologically to intentionally destroy the livelihood and reputation of a foreign worker whistleblower should never be tolerated.  However, ICO (and ActionFraud) practices are so dysfunctional that data subject rights are not protected.  Such practices are very destructive to the data subject, of course.  However, In a broader sense, these practices are harmful to many other global stakeholders.  PGS Exploration (UK) Limited has also violated the human rights of a data subject and his dependents to whom they owed a duty of care.  In the process, PGS Exploration (UK) Limited has lied to multiple governments, investors and competitors.  This has disgraced and made the upstream oil and gas industry less safe and reputable.

As stated within the previous complaint, PGS Exploration (UK) Limited is a UK subsidiary of Norwegian based multinational corporation PGS ASA.  In 2013, three (3) data controllers processed PGS Exploration (UK) Limited SDK personal data to form the termination settlement contract which ended SDKs employment.  Data received by SDK through the 2014 SAR showed that in-house lawyers Carl Richards (Head of PGS UK Legal) and associate Ben Kelly reviewed the termination settlement contract before it was signed.  In-house lawyer Candida Pinto was secretary when most personnel file documents were dated.

SDK hired London based employment law firm Landau Zeffertt and Weir and interacted with principal solicitor Philip Landau and associate Holly Rushton (now Holly Hobson).  Global legal firm Watson Farley and Williams represents PGS Exploration (UK) Limited on a number of matters.  Watson Farley and Williams solicitor Rhodri Thomas was engaged to form and negotiate the final terms and conditions of the termination settlement contract.  All of these named lawyers and experienced HR personnel processed illegal personnel file documents, none of which were accurate or countersigned by data subject SDK.

Since 3 July 2015, SDK has published protected content on the internet exposing not only the inaccurate and illegal personnel file documents.  Since 2016, SDK has published that he was the target of a confidence fraud perpetrated by PGS Exploration (UK) Limited, Watson Farley and Williams and Landau Zeffertt and Weir.  Even though PGS Exploration (UK) Limited threatened legal action with their 22 December 2014 response to the 2014 SAR just because SDK noted the non-compliant / illegal documents that were processed, no action has ever been taken through the English legal system which governed the employment and termination settlement contracts.

PGS Exploration (UK) Limited, Watson Farley and Williams and Landau Zeffertt and Weir (now Landau Law) have never commented directly or specifically about SDK online publications that name and publicly accuse individuals of crimes.  None have invoked a breach in the contract Confidentiality clauses which prohibit publication of disparaging content.  None have processed publications as whistleblowing either.  PGS Exploration (UK) Limited, Watson Farley and Williams and Landau Law compliance have been allowed to provide ridiculous responses to salient concerns about the termination settlement contract process supported by uttered forged defamatory records.  ICO has also never demanded an explanation as to how documents not signed by the data standard are compliant to DPA / GDPR Principles?  This is not protecting subject data rights!

What PGS Exploration (UK) Limited has confirmed is that Jones processed the non-compliant / fraudulent and defamatory SDK personnel file documents while he was in the USA.  SDK believes that the main reason for Jones being provided these non-compliant and defamatory documents was to be allowed to share this data with SDK potential employers who would not want to be liable for negligent hiring.  For instance, if the false records indicate that the employee had falsely accused his employer of illegal harassment and discrimination based on nationality, this would discourage potential employers from offering the candidate a job.  

Blacklisting is illegal in the US state of Texas where Jones resided and was also SDKs US residence whilst employed with PGS Exploration (UK) Limited.  Processing fake employee data is a back door means of blacklisting a whistleblower whose claims were verifiable.  SDK contends that Watson Farley and Williams and Landau Zeffertt and Weir / Landau Law were bribed by PGS Exploration (UK) Limited to process defamatory forged documents as SDKs personal data!  Any experienced employment lawyer or HR professional, such as Jones, knows that personnel file documents not signed by the data subject are not worth a cup of cold urine in a court of law.   

Jones has been an active co-conspirator in UK domestic and US international wire and mail fraud through his processing of knowingly non-compliant and unlawful personnel file records whether as an agent of the US PGS ASA subsidiary or the UK PGS ASA subsidiary.  As current PGS ASA UK subsidiary manager, Jones continues to process this fake SDK data.  However, if Jones’ employer was actually the US PGS ASA subsidiary in 2013-2014, then PGS Exploration (UK) Limited at the very least violated the DPA Eighth Principle and of course lied to both ICO and SDK.  But, ICO has never thought this an important matter to confirm in their defense of SDK subject data rights!

Of course, SDKs counsel Landau and Hobson should have confirmed such facts long ago.  Instead, Landau and Hobson have remained fraudulently silent and refused to provide any answers or clarification to questions asked by former client SDK within multiple online publications.  Landau and Hobson have never addressed the issue of the civil and criminal litigation sponsored by PGS Exploration (UK) Limited.  Landau and Hobson formed the final terms and conditions of the termination settlement contract that ended SDKs employment with PGS Exploration (UK) Limited and was supported by knowingly inaccurate and non-compliant personnel file records which contradict the numerous email communications throughout the negotiation period.

SDK submitted an SAR to Watson Farley and Williams in 2016.  This global law firm did not acknowledge processing SDK personnel file contents.  This is an acknowledgement that Watson Farley and Williams also recognizes that the PGS Exploration (UK) Limited SDK personnel file documents are not legally viable in a court of law and points to the illegitimacy of the termination settlement contract.  Watson Farley and Williams Director of Compliance, Neeta Aulak, does process the termination settlement contract as SDKs personal data.  Aulak also stated that data provided to Watson Farley and Williams for processing the Tier 2 visa application, the legal basis for SDKs employment, was not considered for the termination settlement contract.  Aulak has never commented nor disputed SDKs published claim that she is a lying criminal whore.  

PGS Exploration (UK) Limited, Watson Farley and Williams and Landau Zeffertt and Weir / Landau Law all do not acknowledge processing the grievance document which prompted PGS Exploration (UK) Limited to proffer a settlement contract and not proceed through the legal and contractually guaranteed grievance process.  The termination settlement contract references SDKs submitted grievance, yet none of the inaccurate and unsigned (by the data subject) personnel file documents do.  Even though it is a contractual breach to not proceed through the fair grievance process, PGS Exploration (UK) Limited, Watson Farley and Williams and Landau Zeffertt and Weir / Landau Law bypassed the legal grievance process for a termination settlement contract.  SDKs submitted grievance was whistleblowing.  PGS Exploration (UK) Limited retaliated by bribing lawyers to process forged documents and illegally terminate a whistleblower.

PGS Exploration (UK) Limited, Watson Farley and Williams and Landau Zeffertt and Weir / Landau Law continue to pervert the course of justice through their fraudulent silence.  PGS Exploration (UK) Limited and (former PGS Exploration (UK) Limited secretary) Carl Richards claims against SDK forwarded in Thailand by law firm Duensing – Kippen have prompted no response from Watson Farley and Williams and Landau Zeffertt and Weir / Landau Law.  PGS Exploration (UK) Limited, Watson Farley and Williams and Landau Zeffertt and Weir / Landau Law are trying to escape any relation or accountability for the fraudulent termination settlement contract supported by defamatory forged documents which was proffered to illegally terminate a foreign worker whistleblower.

Corruption is dishonest or fraudulent conduct by those in power that typically involves bribery,  All of the evil and hardship endured by SDK and his family should have been averted had ICO actually confirmed PGS Exploration (UK) Limited compliance to DPA Principles in 2014!  PGS Exploration (UK) Limited, an English company governed by the laws of England, accused SDK of criminal defamation in Thailand under Thai law.  PGS Exploration (UK) Limited has misrepresented legal public disclosure – whistleblowing – as defamation under the laws of Thailand.  

ICO and ActionFraud refuse to ask even the most simple questions to establish GDPR compliance that  protects subject data rights.  And this is why the UKs inept handling of fraudsters fuels corruption and makes the UK less safe and secure.  SDK is simply pleading that ICO pursue their mission to protect data subjects rights.  Ignoring these pleas ensures continued publications exposing PGS Exploration (UK) Limited, Watson Farley and Williams and Landau Zeffertt and Weir / Landau Law crimes.  These publications will also disparage ICO and ActionFraud agents and caseworkers.  The abuse of power includes not using possessed power and resources to fulfil the mission to protect data subject rights.  ICO please demand answers from PGS Exploration (UK) Limited and meet your mission objectives.



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