Anti Bribery and Corruption Policy

It is Pan-n-Ice's policy to comply with the local anti-bribery laws and regulations of all jurisdictions in which we carry on business, and all of our people are required to obey those laws in carrying out their duties. Facilitation payments may not be made by or on behalf of Pan-n-Ice.

It is a criminal offence to give, offer, promise or receive any bribe, not just in relation to government officials. Violations of applicable laws carry severe consequences - civil and criminal - both for the company and the individual employee involved. This policy does not address every situation or deal with the specific laws or regulations that may govern each and every jurisdiction in which Pan-n-Ice currently (or prospectively) does business. You should therefore contact Henry Milroy, Founder, to seek guidance about specific situations should you feel that there is a risk of bribery or a concern you have witnessed and wish to flag.

No Pan-n-Ice, employee or agent may give, or promise to give, money or anything of value to an executive, official, or employee of any (a) government or its agency, (b) political party (including candidates for political office), (c) customer, (d) other organisation (in some cases charitable organisations), or (e) any other company or person if it could reasonably be construed as being intended to influence the company’s business relationship with them. This is anything above what is considered normal within the context of regular business, but bribery may also include meals, gifts, gratuities, entertainment, and other business courtesies.

When dealing with business, all agents or employees of Pan-n-Ice should be mindful of anti-bribery legislation in all dealings with third parties or business partners, as well as in the context of doing due diligence for a new business opportunity, joint venture or partnership. Specific areas of focus should be given to the state of its internal controls and books and records. Pan-n-Ice should obtain written assurances from such third parties that they have not and will not violate anti-bribery legislation during their dealings with us.

Gifts and Hospitality

Gifts or hospitality (whether received or given) may breach our Code of Conduct or anti-bribery legislation if they are (or can be perceived to be) excessive or influence a person to act improperly (such as in awarding a contract as a result of gifts or hospitality).

Management are required to regulate levels of hospitality in a manner proportionate to each business and person.

This guidance helps clarify what is and is not acceptable in respect of gifts and hospitality (whether directly corporate or on behalf of a corporate). Inevitably, some issues are clear cut, but some are less obvious.

Gifts and hospitality must only be of nominal value. This equates to different sums of monitory value in different agencies and countries and from one person to another. It is hard to articulate a specific example that will apply to world over, however once in role you will start to establish what is normal to receive as a business gift and what is deemed lavish. For best practice, if you are gifted anything above a monetary value of £100 you must alert Henry or another member of senior management for them to determine whether the gift is deemed proportionate in relation to the business relationship.

Timing is also a key factor in considering whether there is any bribery. For example, if gifts or hospitality are given or occur in the run up to a bidding decision, the timing may clearly be seen to be seeking influence and would not normally be permitted.

This guidance is not intended to preclude normal working meals of a reasonable cost with a third party.

There will be gifts and hospitality that clearly have a greater value and are not in the "ordinary course". Some gifts and hospitality will be clearly excessive (it is the opinion of the "average man" in the street that is relevant), and there will be a band between clearly acceptable and clearly unacceptable that must be adjudicated between Senior Management.