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Governance & compliance

Anti-Bribery & Corruption

Bribery, improper payments and corrupt practices are not acceptable in the business activities of Pommer & Partners International Trading Limited.

Our principle

We do not offer, promise, give, request or accept payments or other advantages intended to improperly influence a decision, secure preferential treatment or obtain an outcome that would not otherwise be granted. This applies whether the counterparty is a public official or a commercial party, and whether the advantage is money, goods, services or another benefit.

Why it matters in cargo cases

International distressed cargo and salvage cases involve a wide range of parties, and decisions by any of them can affect cost, timing and the viability of a recovery route:

  • Ports and terminals
  • Customs and other border authorities
  • Logistics and transport providers
  • Local agents and representatives
  • Buyers and processors
  • Recycling and disposal contractors

Commercial urgency is not an exception

Distressed cargo often sits under demurrage, storage charges or a deteriorating condition, and delays carry real cost. That pressure does not justify improper payments. Where a case cannot progress lawfully at the speed a party would prefer, the correct response is to accept the delay, escalate through legitimate channels, or decline the case.

Expectations of counterparties and service providers

Buyers, agents, processors, surveyors, logistics providers and disposal contractors engaged in connection with our transactions are expected to conduct their business lawfully and to observe the anti-bribery requirements applicable to them. Where we become aware of conduct inconsistent with this expectation, we may suspend or end the commercial relationship.

Payments, agents and documentation

Payments are made against identifiable services, to identifiable parties, and are recorded in our books. We avoid arrangements in which the purpose of a payment, the identity of the recipient or the service provided cannot be explained.

Status of this statement

This page sets out a corporate principle. It is not a claim of certification to any anti-bribery management standard, nor a claim of regulatory approval or external audit. It is the basis on which our employees, representatives and commercial partners are expected to act.

Questions regarding this information can be directed to the International Cargo Desk at contact@pommerpartners.com or via our contact page.