https://www.caa.co.uk/uploadedFiles/...%20Culture.pdf
Errors and unsafe acts will not be punished if the error was unintentional. However, those who act recklessly or take deliberate and unjustifiable risks will still be subject to disciplinary action.
https://www.vocabulary.com/dictionary/punitive
If by applying just culture, the individuals actions were found to be reckless or unjustifiable risk taking, I would take punitive action.
It seems the courses and reading you've done - were a waste of time Megan.