Anti-Bribery & Corruption Policy
Maintaining integrity and ethical standards in all our business dealings
Zero Tolerance
Pivot Airlines has a zero-tolerance policy for bribery and corruption. We are committed to conducting our business with integrity, transparency, and in compliance with all applicable anti-bribery and anti-corruption laws, including the Canadian Corruption of Foreign Public Officials Act (CFPOA) and the Criminal Code of Canada.
Bribery undermines legitimate business activities, distorts competition, and exposes our company and employees to serious legal consequences. This policy applies to all employees, directors, officers, contractors, and anyone acting on behalf of Pivot Airlines.
Prohibited Activities
- Offering, promising, or giving bribes to any person
- Requesting, agreeing to receive, or accepting bribes
- Making facilitation payments to expedite routine government actions
- Using third parties to channel bribes
- Providing excessive gifts or hospitality that could influence decisions
Gifts & Hospitality
- Gifts must be of nominal value and appropriate to the business relationship
- Hospitality must be reasonable and for legitimate business purposes
- All gifts given or received must be documented and reported
- Cash or cash equivalents are never acceptable
- Gifts to government officials require prior approval
Reporting Obligations
All employees must report any suspected bribery or corruption immediately. Reports can be made to your supervisor, the compliance team, or through our confidential Whistleblower Policy. We will investigate all reports thoroughly and take appropriate action. Retaliation against anyone who reports in good faith is strictly prohibited.
Consequences
Violations of this policy are grounds for immediate termination and may result in criminal prosecution. Pivot Airlines will cooperate fully with law enforcement authorities in any investigation of bribery or corruption.