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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Gender-based violence (GBV) and domestic violence are global issues that affect millions, leaving lasting impacts on survivors, families, and communities. In Ukraine, the ongoing full-scale war has exacerbated these challenges, with factors such as heightened stress, psychological trauma, and economic instability contributing to an increase in reported cases of violence.

Collaborative efforts across sectors are essential for building systems that protect survivors and hold perpetrators accountable. The Police Stabilization Project (PSP), funded by Global Affairs Canada, exemplifies this commitment to collaboration. Working in partnership with Ukraine’s National Police, PSP strengthens law enforcement’s ability to combat GBV and domestic violence. It also supports community safety hubs and partners with civil society organizations to ensure a coordinated response to violence.

Strengthening Law Enforcement

Recognizing the critical role of law enforcement in responding to GBV, PSP launched a training initiative in January 2024. Over the course of 10 workshops, 224 Patrol Police officers—including middle management representatives—enhanced their understanding and skills to address domestic violence and conflict-related sexual violence (CRSV) effectively.

These workshops focused on understanding the dynamics of domestic and sexual violence, improving practical skills for responding to domestic violence calls and building tactical expertise to address challenges in crisis response.

The training equipped officers with the tools to protect survivors, strengthen community safety, and foster public trust.

There were also workshops to strengthen the capacity of investigators and prosecutors. PSP facilitated a series of workshops for over 160 representatives from the investigative departments of the National Police of Ukraine (NPU) and prosecutors to enhance their ability to respond to domestic violence incidents.

Legislative Progress

In addition to these training efforts, Ukraine is taking significant legislative steps to address GBV. On December 19, 2024, new legislation—facilitated by the adoption of the Istanbul Convention—will come into effect, introducing substantial changes to police responses to gender-based and domestic violence.

The law, which was passed in May 2024, aligns Ukraine’s legal framework with international standards for combating violence and represent an essential step toward the country’s integration into the European Union.

The new legislation will introduce updated procedures for responding to gender-based violence, enhance the accountability of perpetrators of domestic violence, sexual harassment, and other forms of GBV. It will also work to strengthen protections for survivors, including children, and implement more stringent penalties for offenders.

“Amid the ongoing full-scale war in Ukraine, the problem of domestic violence has become even more pressing and cannot be ignored. Dedicated efforts are needed to address this issue effectively. I want to extend my gratitude to our friends and partners from the Police Stabilization Project for their steadfast support and long-term collaboration. Together, we have not only raised awareness about domestic violence but also significantly improved the capacity of our police officers to respond to such crimes,” said Oleksiy Biloshytskyi, First Deputy Chief of the Patrol Police Department of Ukraine.

Tom Monastyrski, Director of the PSP, emphasized the collaborative success:

“Together, we have successfully {…} enabled 224 patrol police officers to improve their knowledge and skills in responding to domestic violence. With this training, they are now better equipped to protect and provide assistance to survivors, strengthen community safety, and foster trust within society.”

To raise awareness about these changes, PSP, in collaboration with the Ukrainian Association of Women in Law Enforcement (UAWLE), is launching an information campaign. This campaign will provide Ukrainian law enforcement officers with insights into the new legal norms and operational requirements, ensuring they are prepared to adapt to these updates.

The significance of these efforts is highlighted by leaders from the PSP and Ukrainian law enforcement.

Tackling GBV and domestic violence requires a united effort. The combined impact of international partnerships, new legislation, and robust training initiatives in Ukraine demonstrates that change is possible. These efforts not only enhance the capacity of law enforcement but also provide survivors with the support and justice they deserve.

As part of the global 16 Days of Activism against Gender-Based Violence campaign, the Police Stabilization Project reaffirms its commitment to combating violence and raising awareness. The introduction of updated legislation and continued collaboration across sectors represent pivotal steps toward building safer, more equitable communities.

Together, we can create a future where survivors are supported, perpetrators are held accountable, and violence is eradicated. Because there is #NoExcuse for violence