For us, it's really a matter of violations of deadlines. That's really administrative. The penalties are not related to substantive violations. For example, if someone breaks the rules by taking part in a discussion and putting themselves in a conflict of interest situation, we do not assess a penalty, but an investigation is conducted by the commissioner, followed by a report.
So there are really two standards.
However, the amounts must be taken into consideration. Imposing an administrative penalty of $500 against Air Canada would have no effect in my opinion.