12(1)The arrangements for the plan must not make any provision, or be associated in any way with any provision made, for loans to some or all of the employees of—U.K.
(a)the company, or
(b)in the case of a group plan, of any constituent company.
(2)The operation of the plan must not be associated in any way with such loans.
(3)In sub-paragraph (1) “arrangements” includes any scheme, agreement, undertaking or understanding, whether or not legally enforceable.