Modern Slavery and Human Trafficking Statement

Alinea International Ltd. is a private global development company with corporate offices in Canada, Australia, the United Kingdom, and Luxembourg.

Alinea has a zero-tolerance approach to modern slavery and human trafficking and is fully committed to preventing these illegal activities in our operation and supply chain. The Company has implemented robust safeguarding policies, procedures, and controls designed to ensure that everyone who works with us or for us understands their obligation to conduct business in accordance with the highest ethical standards by protecting and promoting all human rights.

This statement is made pursuant to section 54 (i) of the UK’s Modern Slavery Act 2015. It constitutes Alinea’s modern slavery and human trafficking statement for the financial year ending 30 September 2022.

1 Our Business and Supply Chains

Alinea is an international development consultancy with more than 35 years of experience in this sector. Specialising in social, economic, environmental, and institutional development, the Company works with public organisations and private businesses delivering tailored development, business, and training services worldwide. Alinea manages and participates in short-term missions and longer-term assignments through supporting international teams, as well as individual specialist consultants. We operate in countries which are the recipients of Overseas Development Assistance, many of them fragile or conflict-affected states.

We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and onboarding procedure includes due diligence of the supplier’s reputation, respect for the law, compliance with health, safety and environmental standards, and references.

Our supply chain includes sub-contracted organisations and independent consultants operating worldwide. Our work requires that we develop supply chains in difficult environments, including countries with significant poverty, limited understanding of human trafficking and modern slavery, and limited capability to monitor and deal with human rights abuses including modern slavery. We endeavour to ensure that all our programmes do not support modern slavery through appropriate policies, guidelines, and processes to identify and prevent modern slavery.

2 Assessing and Managing Risk

Alinea has undertaken a modern slavery risk assessment. The nature of our work requires us to operate in countries where there is a high risk of modern slavery and human trafficking, but as providers of technical consultancy services, the overall risk is low.

Our most significant areas of risk lie with our in-country support staff, particularly those on lower incomes or working in Fragile and Conflict Affected States, and amongst similar workers in our supply chains.

We seek to minimise these risks by:

raising awareness of company policies;
consistent enforcement of those policies;
a comprehensive due diligence procedure, and;
a rigorous risk management

3 Policies

Alinea is a member of the United Nations Global Compact and our policies endorse the International Labour Organisation’s {ILO) Declaration on Fundamental Principles and Rights at Work and Forced Labour Convention.

Our comprehensive Codes of Conduct establish the Company’s commitment to respect for human rights and our zero-tolerance attitude towards inaction in the face of any safeguarding abuse. All Alinea staff and business partners agree to be bound by these standards when they undergo due diligence and again when they sign their contracts of engagement.

Policies:

Code of Conduct
Business Partner Code of Conduct
Safeguarding Policy
Whistleblower Policy
Due Diligence Policy
Employment Policy
Recruitment Policy
Risk Management Policy

4 Due Diligence

Alinea International conducts due diligence on all new staff and business partners prior to engagement and periodically thereafter. Our due diligence process for individuals and businesses includes:

a standardized self-declaration questionnaire;
reference checking;
independent third-party screening; and
in-house Internet

Individuals and businesses who have undergone due diligence are added to our list of approved suppliers. Project teams only engage suppliers from the approved supplier lists.

5 Awareness, Training and Monitoring

Before engagement, all new staff and business partners are made aware of the Company’s zero-tolerance attitude to modern slavery and human trafficking via the Codes of Conduct. On induction, all staff receive training across all policies and thereafter annual training is delivered.

Our corporate and in-country offices display a whistleblower poster highlighting areas of concern, which must be reported. This poster is translated into country-specific language to ensure that all staff and visitors to the office can understand the commitment and know how they can raise a concern.

It is Company policy that all significant risks to the Company’s operations should be identified, analysed, evaluated, mitigated satisfactorily, monitored, and regularly reviewed. Each project must complete and maintain a risk register. The risk register is monitored monthly by the project director and periodically reviewed by the Director, Risk Management who in turn reports to the management committee.

Our Business Partners are required to submit an annual declaration confirming that there are no modern slavery practices taking place within their organisation or within their downstream supply chains.

6 Reporting Concerns

Through the Whistleblower Policy, Alinea ensures that safe, appropriate, and accessible means of reporting concerns about modern slavery and human trafficking are made available to our staff and the communities we work with. The Policy specifically includes a commitment to safeguard the identity of any whistleblower and to protect that person against reprisals.

Staff must report any actual or suspected concerns immediately. Our zero-tolerance commitment means that any failure to report a concern could be viewed as gross misconduct and might result in disciplinary action or even dismissal.

Alinea will also accept complaints from external sources such as members of the public, partners, and official bodies. Reports may be made through any of the following channels:

Safeguarding Officer, Shelley Priebe:
shelleyp@alineainternational.com

Director, Risk Management, Charles Duff:
charlesd@alineainternational.com

Through Alinea’s Whistleblower Hotline:
ethics@alineainternational.com

Or through the Company website:
www.alineainternational.com

In addition, where there are suspicions or allegations of improper conduct of any kind in relation to a project funded by the UK Government, a report can be made to:

Foreign Commonwealth and Development Office
Counter Fraud and Whistleblowing Unit (CFWU) at
reportingconcerns@fcdo.gov.uk
Or +44 (0) 1355 843747
Or the Modern Slavery Helpline on 08000 121700
Or website: www.modernslaveryhelpline.org

7 Monitoring Effectiveness

All modern slavery concerns raised with Alinea either via formal or informal mechanisms are referred to the Director, Risk Management and reviewed at management committee meetings. To date there have been no concerns raised about the Company, its staff, or suppliers.

8 The Year Ahead

Alinea commits to:

continuing to protect and promote human rights;
developing a deeper awareness of the risks of modern slavery and human trafficking through targeted training for those involved in higher risk projects;
Developing KPls by against which to measure performance and effectiveness;
An annual review of our systems and processes to ensure effective implementation of our policy on modern slavery and commitment to the Modern Slavery Act 2015.

9 Approval

This statement was considered and approved by Alinea’s management committee and signed by the President on 26 April 2023.

bob-francis-alinea-international-president-signature

Robert Francis.
President & CEO.
Alinea International

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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