alinea’s whistleblower policy

1.1 Purpose

The following Whistleblower Policy has been established to provide guidance to Alinea International employees and sub-contractors on how to deal with known or suspected improper conduct within the organization. The objectives of this Policy are to:

Create awareness of the Policy and available whistleblower protections
Act as a reference guide to potential whistleblowers wishing to make a disclosure
Define the structure of the whistleblower system, including reporting and investigation procedures, whistleblower protections, and confidentiality, among others
Improve the communication and transparency in the processes associated with whistleblowing and assure protection against derogatory consequences, namely reprisals and detrimental action
Complement the current communication channels between employees, sub-contractors and immediate managers, and hierarchical channels flowing to the President and Senior Management team
Provide guidance to all parties involved in either whistleblowing or whistleblower protection.

1.2 Scope

Alinea requires all employees and sub-contractors to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. All employees and sub-contractors of Alinea are required to comply with applicable laws and regulations of Canada and the countries where we operate. Any allegations of known or suspected improper conduct or mismanagement of organizational resources will be dealt with in accordance with this Policy, and reasonable steps will be taken to protect those who come forward with allegations. Alinea’s Whistleblower Policy covers both internal and external whistleblowing, and establishes the controls and procedures for dealing with allegations of malpractice, fraud and violations of our code of ethics and/or laws or regulations that govern our operations. This Policy is intended to encourage employees and sub-contractors to report known or suspected improper conduct or mismanagement of organizational resources and to enable Alinea’s Senior Management team to address and correct inappropriate action. It is the responsibility of all Board of Directors’ members, the Senior Management team, employees and sub-contractors to report concerns about known or suspected malpractice, fraud and violations of our code of ethics and/or laws or regulations that govern our operations. This Policy is applicable to all employees and sub-contractors of Alinea International.

1.3 Reporting Procedures

Alinea recognizes the value of transparency and accountability in its administrative and management practices and supports the making of disclosures that reveal improper conduct or mismanagement of organizational resources. Our internal controls and operating procedures are intended to detect and prevent malpractice, fraud and violations of our code of ethics and/or laws or regulations that govern our operations. As detailed in Alinea’s Employee Policy and Onboarding manuals, employees and sub-contractors are encouraged to share complaints and/or concerns regarding ethical or legal violations with their immediate managers. If the employee or sub-contractor is not comfortable speaking with their immediate manager or is not satisfied with the response, they are encouraged to speak with the Gatineau or Calgary Office Managers, the Vice Presidents or, as required, the Chief Financial Officer. All members of the Senior Management team are required to report complaints and/or concerns about suspected ethical or legal violations in writing to Alinea’s Ethics Committee who has the responsibility to investigate all reported complaints and/or concerns. In the event that the complaint and/or concern is about the President, it should be raised by the employee or sub-contractor to their immediate manager or the Ethics Committee who will determine how the investigation will proceed. All reports will be promptly investigated and appropriate corrective measures will be taken if warranted by the investigation. Alinea’s Ethics Committee is responsible for acknowledging receipt of the suspected violation and notifying the whistleblower of the outcome of the investigation. Anyone filing a written complaint concerning suspected improper conduct or mismanagement of organizational resources must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Personal grievances or complaints related to employment are not covered under Alinea’s Whistleblowing Policy. For cases such as this, employees and sub-contractors are advised to first refer to Alineas Employee Policy and Onboarding manuals when considering a disclosure under the Whistleblowing Policy. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

1.4 Confidentiality

Maintaining confidentiality is crucial to ensure reprisals are not made against the whistleblower. Alinea is committed to safeguarding the identity of the whistleblower and to protecting the whistleblower against detrimental action taken in reprisal for allegations of suspected improper conduct or mismanagement of organizational resources. The Ethics Committee is responsible for ensuring whistleblowers are protected from direct and indirect detrimental action, and that the culture of the workplace is supportive of suspected allegations being made. Any employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment.

1.5 Review

Alinea is committed to implementing ‘best practice’ policies and procedures for dealing with allegations of suspected improper conduct or mismanagement of organizational resources (as defined by this Policy) and the management and protection of whistleblowers making allegation(s). This Policy will be reviewed periodically to ensure it meets the objectives of relevant legislation and remains effective for Alinea, and may be changed at the discretion of the Board of Directors at any time. For allegations of fraud, securities law, or human rights concerns, or when you are not satisfied or uncomfortable with following the Company’s open door policy, individuals should contact the Company’s Ethics Committee directly.

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October is International Strategic Planning Month, celebrated both globally and in Ukraine.

The “Support to Ukraine’s Reforms for Governance” (SURGe) project, funded by the Government of Canada, is actively contributing to this initiative. Since 2019, the SURGe team has been working to implement Results-Based Management (RBM) – a methodology for planning and monitoring public policies. In Ukraine, RBM is now successfully applied at both national and local levels.

This methodology is designed to address social challenges and meet the needs of citizens by focusing on achieving measurable results. By emphasizing clear outcomes, RBM ensures efficient progress toward strategic goals.

Since 2014, Ukraine has made significant strides in adopting the RBM methodology in its strategic planning processes. This shift was initiated by the Government of Canada, which has prioritised building the capacity of Ukrainian public servants in strategic planning as a key area of cooperation.

Thus, over the last 5 years, SURGe has supported the Ukrainian government in developing several key documents using RBM principles and tools. These include the Strategy for the Promotion of the Ukrainian Language, the Strategy for Communication of Euro-Atlantic Integration, the Strategy for the Development of Physical Culture and Sports, the Action Plan for 2023–2024 for the Implementation of the National Barrier-Free Strategy in Ukraine, and the Strategy for Inclusive Education. Notably, the Annual National Programs under the NATO-Ukraine Commission for 2020 and 2021 were also developed using RBM.

Today, RBM is widely applied at both national and local levels in Ukraine. For example, it has been instrumental in the process of preparations of Community Development Strategies for 14 pilot communities as part of the Community-Led Inclusive Recovery (CLIR) initiative, also implemented by the SURGe project. You can learn more about planning processes in communities in the article Community Strategy as Key to Ukraine’s Recovery: How to Build Back Better.

Since 2019, the SURGe team has been supporting the Government of Ukraine in integrating RBM methodology into its operations. This has been achieved through the development of methodological materials, training programs, and direct support in creating strategies and policies tailored to the needs of various social groups. SURGe project has played a crucial role in enhancing the internal procedures of several key ministries and government agencies, including:

the Ministry of Communities and Territories Development,
the Ministry of Culture and Strategic Communications,
the Ministry of Infrastructure,
the National Agency of Ukraine on Civil Service (NAUCS),
the Secretariat of the Cabinet of Ministers,
and Advisor-Presidential Commissioner for Barrier-Free Environment.

During this period, the SURGe team helped embed RBM and GBA+ into the policy development process. This integration has been supported through the creation of methodologies, tools, and templates, which have since been formalized in official procedures, such as the Procedure for the Development, Monitoring, Reporting, and Evaluation of the Action Plans for the Ministry of Communities and Territories Development, the Instruction for Integrating Gender-Based Approaches in Legal Acts, approved by the Ministry of Social Policy. In partnership with NAUCS and the Ministry of Social Policy, SURGe also developed and approved a Guide on Implementing Gender-Based Approaches in the Civil Service.

Moreover, the SURGe team has supported the development of the Action Plan for 2023-2024 for the implementation of the National Strategy for a Barrier-Free Environment in Ukraine up to 2030. SURGe continues to provide ongoing support for its progress monitoring and is actively assisting in the creation of regional strategies aimed at fostering barrier-free environments.

Training public servants in the principles of RBM and GBA+ has been another key component of the SURGe Project work. In collaboration with NAUCS, the SURGe team developed several training programs, which have been delivered by Project experts to public servants across various sectors. In total, between 2019 and 2024, SURGe experts have trained over 7,000 civil servants in strategic planning using RBM principles.

In a time when Ukraine’s path toward European integration, necessary reforms, and the effective recovery of war-affected communities are more critical than ever, these efforts are vital.