Governance & compliance
Business Ethics
Pommer & Partners International Trading Limited operates in international cargo recovery, salvage and trading markets where decisions are often taken quickly and under commercial pressure. The principles below describe how we expect our own conduct to be judged.
Integrity in commercial conduct
Distressed cargo cases frequently involve incomplete information, damaged goods and competing commercial interests. We aim to describe what we know, state what remains uncertain, and avoid creating expectations about outcomes, values or timelines that cannot be supported by the facts of the case.
Our commercial role
In many transactions Pommer & Partners acts as principal buyer, purchasing cargo on an 'as is, where is' basis for our own account and at our own commercial risk. Where we purchase cargo we have our own commercial interest in the transaction and do not present ourselves as an independent adviser to the seller. In other transactions we may act as a remarketing or recovery coordinator. We state which role applies in each case.
Transparency and information
Offers, deductions, cost assumptions and intended recovery routes are set out so a counterparty can assess them. Where survey findings, laboratory results or customs status change the commercial picture, we revisit the position rather than rely on an earlier assumption.
Confidentiality
Case information — cargo details, claim background, commercial values, counterparty identities and internal documentation — is treated as confidential and used for the purpose of the case. Where third parties such as surveyors, laboratories, processors or logistics providers must be involved, information shared with them is limited to what the task requires.
Conflicts of interest
Cargo recovery markets are small, and the same parties recur across cases. We seek to identify situations where our interests, or the interests of two counterparties, could conflict, disclose the position to those affected, and decline or restructure the engagement where a conflict cannot be managed appropriately.
Fair treatment of counterparties
Cargo owners, insurers, brokers, loss adjusters, carriers, terminals, buyers and service providers are dealt with consistently. Commercial urgency, storage pressure or a deteriorating cargo condition are not used as a basis for conduct we would not be prepared to explain afterwards.
Compliance with applicable law
Transactions are structured to comply with the laws and regulations applicable to the cargo, the jurisdictions involved and the parties concerned. Where a commercially attractive route would conflict with those requirements, it is not pursued. Related principles are set out under Anti-Bribery & Corruption, Sanctions & Compliance and Responsible Trading.
Responsible decision-making
These are corporate principles rather than a certification, audit outcome or regulatory authorisation. They describe the standard we hold ourselves to and the basis on which we expect to be held accountable by our counterparties.
Questions regarding this information can be directed to the International Cargo Desk at contact@pommerpartners.com or via our contact page.