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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Colombia is one of the world’s longest-standing mining jurisdictions, but outdated government systems created barriers for Colombians to receive benefits from the sector. One of these systems was the Colombian Mining Cadaster with inaccurate information, data processing errors and no interaction with other government departments – making transparent and evidence-based decisions in mining near impossible.

As part of the Comunica Project, funded by Global Affairs Canada, Alinea collaborated with Colombia’s National Mining Agency to develop and deliver AnnA Mineria – an online integral mining management platform to improve the lives of Colombians through transparent and responsible management of the country’s natural resources. “Comunica” is the Building Extractive Sector Governance in Colombia Project.

Digital transformation

Implemented in September 2020, AnnA Mineria is entering its first full year in operation. This e-government system digitizes all processes involved in granting mining titles. Industry users apply for and manage mining concessions, make royalty payments and view mining inspection reports. Government users view industry documents, make requests, grant mining concessions, collect royalties, steward environmentally sensitive areas and upload reports. Everything is standardized – reducing processing times by up to 80 per cent.

Users can also perform online queries and view active titles, areas available and prohibited for mining, as well as environmentally protected areas. The system supports the collection and use of gender disaggregated data, which allows the Government of Colombia to identify the demographics of users so mining can actively reduce gender inequality in Colombia – aligned with Canada’s Feminist International Assistance Policy.

“AnnA Mineria is a tool that transforms the relationship between the state and the public in information sharing and environmental mining management, which allows greater transparency,” said Iván Duque, President of Colombia.

New investment

In AnnA Mineria’s first three months of operation, more than 16,600 users registered and the system received 8,000 applications for mining concessions. This translates into $250M CAD of new investment committed by the private sector to new mining projects in Colombia.

In December 2020, AnnA Mineria received a #LatamDigital Award as one of the best digital transformation projects in the category of best government support for digital SMEs.

International cooperation

“With cutting-edge technology, we are digitizing decision-making and environmental management of mining to make this sector work for all Colombians,” said Shantel Jordison, Comunica Project Director.

AnnA Minería represents a digital transformation in the Colombian mining sector and an e-government milestone in Latin America – the result of international cooperation between the Government of Canada and Government of Colombia. Alinea worked closely with the Colombian National Mining Agency and Ministry of Mines, as well as Pacific Geotech Systems, a Victoria-based software company, to build AnnA Minería and provide technical assistance and capacity development to ensure long-term sustainability of the system and benefits to Colombians for decades to come.