在控告書中舉證殼牌阿根廷公司（公然違反）經濟合作開發組織（Organization for Economic Cooperation and Development, OECD）所發行的多國企業指導綱領。
此外，控告書也要求殼牌石油公司必須採取立即的行動，在過去幾十年來，因為其位於Polo Petroquérico Dock Sud的石油精煉廠濫用及不負責任的企業行為，而對整個社區所造成社會和環境的傷害，必須給予補償。
當地非政府組織Foco Inpade以及阿根廷地球之友（Friends of the Earth Argentina）也代表Inflamable村的居民發聲，針對殼牌阿根廷公司的違法行為，其已分別向阿根廷政府和荷蘭政府提出控告書。
Following a scathing government audit of the Argentine affiliate of Royal Dutch Shell and a globally unprecedented preventive closure of its refinery in Buenos Aires, local groups Wednesday filed a formal international complaint against the company seeking relocation and redress.
The complaint cites Shell Capsa "for the flagrant and officially documented violation" of the Guidelines for Multinational Enterprises issued by the Organization for Economic Cooperation and Development, OECD.
The complaint calls for immediate action by the company to redress the social and environmental harms caused to the community and to the local environment by the refinery at the Polo Petroquérico Dock Sud during decades of abuse and irresponsible corporate behavior.
Representing the residents of Villa Inflamable, the local nongovernmental organizations Foco Inpade and Friends of the Earth Argentina presented parallel complaints to the governments of Argentina and the Netherlands against Shell Capsa, Shell's Argentine affiliate.
The Shell Capsa facility occupies a total of 106 hectares in the Matanza Riachuelo Basin and is the only refinery in South America belonging to the Shell Group.
It is located four kilometers from the center of Buenos Aires, in the suburban locality of Avellaneda, where the inhabitants are described in the complaints as suffering from "extreme socio-economic vulnerability" which has evolved over time and in parallel to the petroleum refinery industry, largely dominated by Shell.
The crude oil is transported from the oil fields to the refinery primarily by sea, although some is transported by pipeline. Shell Capsa has its own fleet of ships that unload the raw material at its dock for flammable materials near the refinery, from which the crude oil is pumped into storage tanks to be processed.
Shell also owns two gas plants which obtain butane, propane, and propylene.
The complaints denounce Shell for a long list of national, provincial, municipal and international law violations that are not only claimed by the community against the company, but that have been confirmed in an audit carried out in August and September 2007 after accidents that occured at the facility on August 2, 2007, generating hazardous waste.
The National Environmental Authority of Argentina then ordered a preventive closure of the facility for failure to comply with national environmental laws.