Code of Conduct

1. Our Commitment

Travel Tripper LLC d/b/a Pegasus (“Company” or “Pegasus”) stands for honesty, open communication, fairness and trustworthiness. More than ideals; these are the essence of our business policy. They are standards that every one of us must strive to meet in all business dealings and conduct.
Our high business standards will be more effectively carried out in practice if there is a clear expression and understanding of the kinds of conduct that are in line with and against company policy. That is the purpose of our Code of Conduct (“Code”).

It is the responsibility of every one of us to read this Code; to understand it; to comply with all applicable laws, rules and regulations; and to comply with all provisions of this Code and its related policies and procedures. Each of us must report any violations of laws, rules, regulations, of this Code to the appropriate personnel. Failure to report violations and failure to follow the provisions of this Code may have serious legal ramifications and you may be disciplined by the Company. Disciplinary actions may include termination of your employment.
One indication of how seriously we take this Code is that we have established a Compliance Portal that our employees and agents may use to report violations or to ask questions regarding the Code. The portal is found at https://go.pegasus.io/whistleblower. Submissions may be confidential and anonymous.

  • After reading this Code, you should:
  • Have a thorough knowledge of the Code’s terms and provisions.
  • Be able to recognize situations that present legal or ethical dilemmas.
  • Be able to deal effectively with questionable situations in conformity with this Code.

In order to accomplish these goals, you should:

  • Read the entire Code thoroughly.
  • If there are references to more detailed policies that are not contained in this Code, obtain and read those policies if they apply to you.
  • Think about how the provisions of this Code apply to your job, and consider how you might handle situations to avoid illegal, improper, or unethical actions.
  • If you have questions or are faced with a situation where you are not clear as to what action you should take, ask your supervisor, the Human Resources Department, the Legal Department, or submit your issue or question in the Compliance Portal.

2. FairDealing

We have built a reputation as a trustworthy and ethical member of our community and our industry. We are committed to maintaining the highest levels of integrity and fairness within Pegasus and all of its worldwide subsidiaries. When we fail to negotiate, perform or market in good faith, we may seriously damage our reputation and lose the loyalty of our customers. That’s why we insist that you conduct business honestly and fairly. You should endeavor to deal fairly with our customers, contractors, vendors and even our competitors. You should not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair-dealing practice.

3. Legal Compliance

First and foremost, our policy is to behave in an ethical manner and comply with all laws, rules and government regulations that apply to our business. The legal topics addressed below are an important part of compliance throughout our operations around the world. However, this Code of Conduct does not address every possible situation or cover every legal topic in detail. It is your responsibility to know and follow the law in your jurisdiction and conduct yourself in an ethical manner.

Antitrust Laws. Antitrust laws are designed to ensure a fair and competitive marketplace by prohibiting various types of anticompetitive behavior. Some of the most serious antitrust offenses occur between competitors, such as agreements to fix prices or to divide customers, territories or markets. Accordingly, it is important to avoid discussions with our competitors regarding pricing, terms and conditions, costs, marketing plans, customers, and any other proprietary or confidential information. Foreign countries often have their own body of antitrust laws, so our international operations may also be subject to antitrust laws of other countries.

An Unlawful agreement does not need to be written. It can be based on informal discussions or the mere exchange of information with a competitor. If you believe that a conversation with a competitor enters an inappropriate area, end the conversation at once.

Although the Company generally encourages employee personal membership in professional and trade associations, you may come in contact with competitors’ employees through these groups. Never discuss proprietary or sensitive competitive issues such as prices, costs, terms or conditions of sale or service, product plans, or any other competitively sensitive or non-public information.

Anti-Corruption Laws. The U.S. Foreign Corrupt Practices Act (FCPA) and Company policy prohibit us from directly or indirectly making or offering payments to government officials for the purpose of gaining business or favorable government action. Prohibited payments need not take the form of cash. They may be anything of value, including gifts, services and favors. Generally speaking, small business courtesies such as lunches intended only to promote general goodwill are not prohibited. In every case, we are required to maintain accurate records and internal controls to assure compliance with U.S. law on this subject.

The U.K. Anti-bribery Act is similar to the FCPA but it is more strict and far-reaching. The UK Anti-bribery Act prohibits bribes to government officials and prohibits bribes to those working in the private sector (e.g. a hotel owner/operator).

Our Statement of Ethics, Anti-Corruption and Anti-Bribery policies set out in detail how you should behave and what you should do if you are confronted with corruption.

Political Contributions. We will fully comply with all political contribution laws. Our funds may not be used for contributions of any kind to any political party, committee, candidate, or holder of any government position (national, state or local) unless such contribution is permitted by law and complies with our Company policy. It is also against our policy to reimburse an employee for any political contributions or expenditures. Please contact our Legal Department to determine whether a specific company contribution is permitted.

International Trade and Transactions. In the conduct of both U.S. and non-U.S. operations, the Company intends to fully comply with all applicable U.S. laws governing imports, exports and the conduct of business with non-U.S. entities. These laws contain limitations on the types of products that may be imported into or exported from the United States and the manner of importation. For more detailed guidance on such laws and the countries to which they pertain, contact the Legal Department.

This discussion is not comprehensive and you are expected to familiarize yourself with all laws and regulations relevant to your position with us, as well as all our related written policies on these laws and regulations. If you need further information or explanations regarding any laws or regulations, contact the Human Resources Department or the Legal Department.

4. Respect for Human and Labor Rights.

The Company respects compliance with internationally recognized human rights and ensures that breaches or abuse of these rights do not take place in its business operations. The potential for any indirect human rights violations should also be considered with all business dealings. Employees are to be treated with dignity and respect. Physical or psychological punishment, harassment of any kind and abuse of power will not be permitted under any circumstances, respecting basic labor rights at all times.

Prohibition of child labor and forced or coerced labor. The Company will not contract minors or permit any form of forced or involuntary labor. For the purposes of this Code, a minor is defined to be a person under the age of 16 years old, unless the applicable national legislation establishes a higher age limit, in which case the said limit will be respected. Youth workers must not work on night shift or under dangerous conditions.

Equal Opportunity, Non-Discrimination & Anti-Harrassment. The Company maintains a worldwide commitment to providing all qualified individuals an equal opportunity for employment. It is the Company’s intent to maintain a diverse and inclusive work environment that is free of harassment, discrimination, and retaliation. The specific requirements and protected categories of this general policy vary throughout the many legal jurisdictions in which the Company operates, however is inclusive of prohibiting discrimination of any form on the basis of age, disability, pregnancy, race, religion, sex, and sexual orientation. Employees should refer to the appropriate local policy for the specific rules and all other applicable protected categories that apply to their location.

Respect for employee’s rights of association, to join a trade union, organize themselves or negotiate collectively without any kind of sanctions. The Company respects its employees’ rights of association, affiliation and collective bargaining. Workers’ representatives will be allowed to carry out their duties of representation at the workplace without discrimination. When the right to freedom of association and to collective bargaining is restricted by law, the Company will not hinder the development of parallel forms of association and free and independent bargaining.

Respect for maximum working hours, established minimum salaries and other ruling legislation. The Company will adapt the duration of the working day to the provisions of applicable legislation and/or the terms and conditions of the applicable collective bargaining agreement. The payment and performance of overtime must respect the provisions established in applicable legislation.

Salaries and benefits paid for the work must be paid and must respect the minimum salaries and/or national legal standards or the standard industry parameter, whichever is higher. All deductions from salary in respect of disciplinary measures must be in accordance with the applicable national legislation.

The Company will not curtail the rights of workers recognized in labor and social security legislation.

Guarantee that employees carry out their work in employment conditions of health and safety, respecting risk prevention legislation. The Company shall provide workers with a safe and healthy workplace, taking into consideration at all times prior knowledge of the industry and specific hazards, guaranteeing minimum conditions of light, ventilation, health, hygiene and safety measures. Suitable measures will be adopted to prevent accidents or damage to health deriving from, associated to or as a result of the work.

5. Respect for the Environment

The Company shall obtain and maintain any required environmental permits for its business operations. The Company favors the development and dissemination of technologies that respect the environment and strives to adopt methods that benefit greater environmental responsibility whenever possible.

6. Accurate and Complete Financial Reporting

All information you record or report on our behalf, whether for our purposes or for third parties, must be done accurately and honestly. All of our records (particularly including accounts and financial statements) must be maintained in reasonable and appropriate detail, must be kept in a timely fashion, and must appropriately reflect our transactions. When a payment is made, it can only be made for the purpose spelled out in the supporting document. Falsifying records or keeping unrecorded funds and assets is a severe offense and may result in prosecution or loss of employment.

Information derived from our records is provided to our shareholders and investors as well as government agencies. Accordingly, our accounting records must conform not only to our internal control and disclosure procedures but also to generally accepted accounting principles and other laws and regulations, such as those of the Internal Revenue Service or Her Majesty’s Revenue & Customs (HMRC) in the UK. In this regard, all officers and employees involved in the preparation of such reports should become familiar with and adhere to the Company’s disclosure controls and procedures. To further ensure the integrity of our data, all employees should comply with all internal controls of the Company applicable to their activities.

Our external auditing functions help ensure that our financial books, records and accounts are accurate. Therefore, you should provide our Accounting Department, Audit Committee and independent public accountants with all pertinent information that they may request. We encourage open lines of communication with our Audit Committee, accountants and auditors and require that all our personnel fully cooperate with them. It is unlawful for you to fraudulently influence, induce, coerce, manipulate, or mislead our independent public accountants for the purpose of making our financial statements misleading.

7. Company Records & Assets

We will retain all books, records and statements in accordance with our record retention policies and all applicable laws and regulations. From time to time we are involved in regulatory or legal proceedings that may require us to make some of our records available to third parties. Our Legal Department will assist us in releasing appropriate information to third parties and provide you (or your supervisor) with specific instructions. It is a crime to alter, destroy, modify, or conceal documentation or other information that is relevant to a government investigation or otherwise obstruct, influence or impede an official proceeding. The law applies equally to all of our records, including formal reports as well as informal data such as e-mail, expense reports and internal memos. If the existence of a subpoena or a pending government investigation is known or reported to you, you should immediately contact our Legal Department and you must retain all records that may pertain to the investigation or be responsive to the subpoena.

Company property, electronic communication systems, information resources, material, facilities, equipment, intellectual property and other assets must be used and maintained with the utmost care and respect. You should be mindful to protect these assets against theft, waste and abuse, and report suspected violations. You should also use assets in a manner that does not infringe on the rights of others, particularly by complying with applicable software licenses and copyright laws.

8. Conflicts of Interest

All of us must be able to perform our duties and exercise judgment on behalf of our Company without inappropriate or improper influence, or the appearance of inappropriate or improper influence, due to any activity, interest or relationship that arises outside of work. Put simply, when our loyalty to our Company is affected by actual or potential personal benefit or influence from an outside source, a conflict of interest exists. We should all be aware of and avoid any potential influences that impact or appear to impact our loyalty to our Company.

Any time you believe a conflict of interest may exist (including the specific examples described below), you must disclose the potential conflict of interest to our Legal Department. It is not possible to describe every conflict of interest, but some situations that could cause a conflict of interest include the following categories.

Doing Business with Family Members. A conflict of interest may arise if family members work for a supplier, customer or other third party with whom we do business. It also may be a conflict if a family member has a financial interest in a supplier, customer or other third party with whom we do business. “Family members” include your: spouse, brothers or sisters, parents, in-laws, children, or a life partner.

Employing relatives or close friends who report directly to you may also be a conflict of interest. Although our Company encourages employees to refer candidates for job openings, employees who make or influence a hiring decision must avoid giving an unfair advantage to their relatives and close friends.

Ownership in Other Businesses. Personal investments can cause a conflict of interest. It may be a conflict of interest if you own, directly or indirectly, a financial interest in any company that does business with us, seeks to do business with us or is one of our competitors. Notwithstanding the foregoing, non-employee directors of our Company and their family members may have financial interests in or be affiliates of suppliers, customers, competitors and third parties with whom we do business or propose to do business. However, such non-employee directors must disclose any such relationship promptly after the director becomes aware of it, and otherwise act in a manner consistent with the director’s fiduciary duties.

Outside Employment. Sometimes our employees desire to take additional part-time jobs or do other work after hours, such as consulting or other fee-earning services. This kind of work does not in and of itself violate our Code. However, the second job must be strictly separated from your job with us, and must not interfere with your ability to devote the time and effort needed to fulfill your duties to us as our employee. You cannot engage in any outside activity that causes competition with us or provides assistance to our competitors or other parties (such as suppliers) with whom we regularly do business. You should endeavor to avoid outside activities that embarrass or discredit us. Outside work may never be done on Company time and must not involve the use of our supplies or equipment. Additionally, you should not attempt to sell services or products from your second job to us.

Community Service. The Company generally encourages its employees to make contributions of time and financial resources to charitable and community service organizations. However, this service must not interfere with your ability to devote the time and effort needed to fulfill your duties to us as our employee, should not be done on Company time and must not involve the use of our supplies or equipment. You must also be alert to potential conflicts of interest between the Company and the charity.

Service on Boards. Serving as a director of another company may create a conflict of interest. Being a director or serving on a committee of some organizations, including government agencies, also may create a conflict. This risk is particularly significant with respect to for-profit organizations but may also apply to non-profit organizations.

Business Opportunities. Business opportunities relating to the kind of business we are in or the activities we typically pursue that arise during the course of your employment or through the use of our property or information belong to us. Similarly, other business opportunities that fit into our strategic plans or satisfy our commercial objectives that arise under similar conditions also belong to us. You may not direct these kinds of business opportunities to our competitors, to other third parties or to other businesses that you own or are affiliated with.

Gifts and Entertainment. We are dedicated to treating fairly and impartially all persons and firms with whom we do business. Therefore, our employees must not give or receive gifts, entertainment or gratuities that could influence or reasonably be perceived to influence business decisions. Misunderstandings can usually be avoided by conduct that makes clear that our Company conducts business on an ethical basis and will not seek or grant special considerations.

Accepting Gifts and Entertainment: You should never solicit a gift or favor from those with whom we do business. You may not accept gifts of cash or cash equivalents. You may accept novelty or promotional items or modest gifts related to commonly recognized occasions, such as a promotion, holiday, wedding, or retirement, if: (i) this happens only occasionally; (ii) the gift was not solicited; (iii) disclosure of the gift would not embarrass our Company or the people involved; and (iv) the value of the gift is under US$100.

You may accept an occasional invitation to a sporting activity, entertainment or meal if: (i) there is a valid business purpose involved; (ii) this happens only occasionally with any particular business party; and (iii) the activity is of reasonable value and not lavish. You may also accept gratuitous accommodations from hotel companies for limited stays if there is a valid business relationship or potential relationship involved.

Giving Gifts and Entertaining: Gifts of nominal value (under US$100) and reasonable entertainment for customers, potential customers and other third parties with whom we do business are permitted. However, any gift or entertainment must: (i) support our Company’s legitimate business interests; (ii) be reasonable and customary, not lavish or extravagant; and (iii) not embarrass our Company or the recipient if publicly disclosed.

Under no circumstances can any bribe, kickback, or illegal payment or gift of cash or cash equivalents be made. Also, special rules apply when dealing with government employees. These are discussed in this Code under “Compliance with Laws – Anti-corruption Laws.”

9. Confidentiality

Subject to variation based on legal jurisdiction, all Company employees are required to sign a Confidential Information and Invention Assignment Agreement as a condition of employment, which should be read carefully before signing. The agreement includes specific commitments on the employee’s part regarding confidential information, inventions, conflicts of interest, at-will employment, and other matters. Persons leaving the Company’s employment for any reason will be asked to sign a statement that they have returned all confidential information previously in their possession. The Confidential Information and Invention Assignment Agreement also provides that a former employee’s obligation to safeguard confidential information continue after their departure from the Company. Persons who improperly use or disclose confidential information will be subject to disciplinary action, up to and including termination of employment, and the Company may take legal action to enforce this policy.

10. Administration of the Code

Applicability & Distribution. This Code applies to all employees and officers of the Company worldwide, as well as to the directors of the Company except where expressly limited. The Code, including any updated versions, will be posted on our Internal HR drive and may be distributed to all employees, officers, directors, stockholders, vendors, customers, and other interested parties.

Role of Supervisors and Officers. Supervisors and officers have important roles under this Code and are expected to demonstrate their personal commitment to this Code by fostering a workplace environment that promotes compliance with the Code and by ensuring that employees under their supervision participate in our Company’s compliance training programs.

Reporting Violations. All employees are obliged to report violations of this Code or the law and to cooperate in any investigations into such violations. We prefer that you give your identity when reporting violations. However, you may anonymously report violations through the Company’s Compliance Portal.

No Retaliation. We will not retaliate against anyone who, in good faith, notifies us of a possible violation of law or this Code, nor will we tolerate any harassment or intimidation of any employee who reports a suspected violation. Any attempt at retaliation will itself be a violation of this Code, which should be reported via the Compliance Portal or otherwise. In addition, there are federal “whistleblower” laws that are designed to protect employees from discrimination or harassment for providing information to us or governmental authorities, with respect to certain laws such as those relating to financial reporting and workplace safety.

Investigations. We will initiate a prompt investigation following any credible indication that a breach of law or this Code may have occurred. We will also initiate appropriate corrective action as we deem necessary, which may include notifying appropriate authorities. For more information about our procedures in dealing with violations or suspected violations of this Code, you should contact our Human Resources Department.

Disciplinary Action. If you violate any provision of this Code, you may be subject to disciplinary action, up to and including termination of employment. Please be aware that we may seek civil remedies from you, and if your violation results in monetary loss to us, you may be required to reimburse us for that loss. If you are involved in a violation, the fact that you reported the violation, together with the degree of cooperation displayed by you and whether the violation is intentional or unintentional, will be given consideration in our investigation and any resulting disciplinary action.

Approvals. All approvals required under this Code should be documented.

Waivers. Because our commitment to this Code is so strong, we will only grant waivers of it under the most unusual or compelling circumstances. Therefore, we expect that waivers will be granted very infrequently. If you would like to request a waiver of this Code for any reason, you must submit a detailed written statement to your supervisor, Human Resources and our Legal Department describing the nature of your request and explaining why you believe the waiver is appropriate.

Complying with the Code. This Code summarizes certain laws and sets forth the ethical policies that apply to all of our employees, officers and directors worldwide. Several policy summaries in this Code refer to more detailed policies that either (1) concern more complex Company policies or legal provisions, or (2) apply to select groups of individuals within our Company. If these detailed policies are applicable to you, it is important that you read, understand, and comply with them. If you have questions as to whether any detailed policies apply to you, contact your supervisor or the Human Resources Department.


Note that this Code is not an employment contract or other contract between the Company and any employee and does not modify the employment relationship between the Company and any employee. This Code is not a guarantee of any specific policies, practices, procedures, standards, length of employment or other terms of employment.

The Company may change, interpret, withdraw, or add to the policies and practices described in this Code at any time without prior notice to and without approval from any employee. That being said, issues of integrity, credibility and trustworthiness are core values that will not be amended, altered or revised1.


1 This updated version is effective 11.2021

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