Modern Slavery & Human Trafficking Policy

Zero tolerance for exploitation in any form

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Our Commitment

Pivot Airlines has zero tolerance for modern slavery, human trafficking, and any form of forced labour. We are committed to acting ethically and with integrity in all our business dealings and relationships, implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place anywhere in our operations or supply chains.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced and compulsory labour, and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

Prohibited Practices

  • Human trafficking in any form
  • Forced or compulsory labour
  • Debt bondage or indentured servitude
  • Child labour or exploitation
  • Deceptive recruiting practices
  • Withholding of identity documents
  • Restriction of movement or communication
  • Threats, intimidation, or coercion

Due Diligence Measures

  • Risk assessments of our operations and supply chains
  • Supplier screening and contractual requirements
  • Employee training on identifying warning signs
  • Regular audits and compliance monitoring
  • Grievance mechanisms for reporting concerns
  • Remediation procedures when issues are identified

Recognizing Warning Signs

Potential Indicators of Exploitation

Workers who appear fearful, anxious, or submissive
Evidence of control over workers by third parties
Workers living in degraded or overcrowded conditions
Workers lacking personal possessions or ID documents
Inconsistent or scripted responses when questioned
Signs of physical abuse or malnourishment

Supply Chain Standards

We require all suppliers and contractors to comply with our anti-slavery standards. Contracts include specific clauses prohibiting the use of forced, compulsory, or trafficked labour, and we reserve the right to audit compliance.

Reporting Concerns

If you suspect modern slavery or human trafficking in our operations or supply chain, please report it immediately. Use our Contact Us form or speak with your supervisor. All reports will be treated confidentially.

Training & Awareness

All employees receive training on modern slavery awareness, including how to identify potential victims and what to do if they suspect exploitation. Additional specialized training is provided to employees in high-risk roles, including procurement, HR, and operations personnel.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, contractors, consultants, and business partners.

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