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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PROTECT2 Joins the 16 Days of Activism Against Gender-Based Violence Campaign to raise awareness, advocate for systemic change, and protect vulnerable communities in Ukraine.

Led by Alinea International and funded by Global Affairs Canada, PROTECT2 works in close partnership with the Government of Ukraine, including the Ministry of Defence, to strengthen institutions within the defense sector. The project embeds internationally recognized standards of governance, gender equality, accountability, and performance, driving measurable progress toward democratic governance and improved resource management.

The 16 Days of Activism campaign serves as a powerful call to eliminate violence against women and girls worldwide. PROTECT2 stands at the forefront of developing innovative solutions to prevent and address gender-based violence (GBV) in the context of conflict.

Supporting Survivors Through Justice and Collaboration

A critical component in combating GBV is ensuring that justice systems prioritize survivors. To this end, PROTECT2 collaborates with the National Academy of Internal Affairs and the Government Commissioner for Gender Policy to develop victim-centered guidelines for judicial investigations of sexual violence during armed aggression. These guidelines aim to uphold survivors’ dignity and provide a framework for effective, compassionate justice.

Empowering Change Through Education and Awareness

Education and training are at the heart of PROTECT2’s approach. The project trains gender advisors within Ukraine’s defense sector, equipping them with the tools to address and prevent GBV effectively. PROTECT2 also integrates combating GBV into broader gender equality training, ensuring this issue remains a top priority.

Looking ahead, PROTECT2 is launching an online course on gender equality tailored for the Armed Forces of Ukraine. The course includes comprehensive modules on GBV prevention and response, fostering greater understanding and capacity among military personnel. To support civilians affected by conflict-related sexual violence, PROTECT2 has also created and distributed a memo offering practical, survivor-centered engagement strategies.

Driving Strategic Change and International Alignment

PROTECT2 contributes to systemic change through its support for strategic frameworks and working groups, such as the Interagency Working Group on Combating Sexual Violence Related to Russia’s Armed Aggression. By aligning its initiatives with national and international priorities, PROTECT2 plays a key role in addressing GBV in conflict settings.

Further international alignment includes advocacy and workshops. For instance, the NGO Women in Defence, with support from PROTECT2, is hosting the workshop “Justice Without Compromise: The UN and NATO Zero-Tolerance Approach.” This event highlights global standards for addressing sexual violence, emphasizing collaboration and knowledge-sharing to strengthen international responses to GBV.

This year’s 16 Days of Activism campaign is a rallying cry to prevent GBV, protect survivors, and advocate for systemic change. Through initiatives like PROTECT2, we can create a safer, more equitable world. Learn more about PROTECT2’s work here: PROTECT2 Overview.

#16Days #EndGBV #JusticeForAll #Ukraine