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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The Impact of the Police Stabilization Project

Since the beginning of the full-scale invasion in 2022, Ukraine has faced unprecedented challenges in maintaining public safety and supporting vulnerable communities. In response, the Police Stabilization Project (PSP) has actively worked to enhance security and build trust between law enforcement and local populations. A key component of this effort has been the establishment of community safety hubs, which serve as trusted spaces for collaboration between police and civil society organizations.

These safety hubs build upon earlier efforts dating back to 2019 when PSP partners launched Community Consultative Groups to address local safety challenges. Today, nine Ukrainian communities benefit from these hubs, which provide a range of social, legal, and mental health services. They also function as platforms for community discussions on safety, fostering cooperation between law enforcement, local service providers, and residents.

A Landmark Conference on Community Policing

To showcase the progress made and exchange best practices, the PSP organized the “Working Together for Safer Communities” conference in November 2024. This event brought together key stakeholders, including civil society representatives, police officers from safety hubs across nine regions, officials from the National Police of Ukraine (NPU) and the Patrol Police of Ukraine, as well as international partners and donors.

The conference highlighted the importance of building trust between police and citizens, sustaining effective partnerships, and providing critical support amid wartime conditions. Yulia Bersymenko, the Community Safety Component Lead of PSP, addressed attendees, stating:

“With the PSP, you have made significant progress and implemented numerous impactful initiatives in your communities. These efforts have evolved into sustainable partnerships with the police. Today, all of you have established your own safety hub, which serves as a focal point for safety in your community.”

Throughout the event, participants shared inspiring stories of how safety hubs support local communities. From organizing self-defense and first aid courses to assisting survivors of violence and integrating internally displaced persons, these initiatives are making a tangible impact. Safety hubs have also evolved into cultural and educational spaces, fostering meaningful change and resilience in the face of adversity.

PSP Director Tom Monastyrski emphasized the importance of these initiatives:

“We are grateful to everyone who has contributed to implementing local safety initiatives under such challenging circumstances. Safety hubs play a significant role in creating a safe environment in Ukrainian communities. Each success story of assistance and support within these hubs demonstrates how trust-based initiatives can effectively address local safety challenges during times of war.”

The conference concluded with a recognition of the invaluable contributions of PSP partners in fostering community safety and advancing the principles of community policing in Ukraine. Their dedication has laid the groundwork for continued progress in building safer and more resilient communities.

Introducing the Community Policing Knowledge Hub

Building on these achievements, the PSP is excited to announce the launch of the Community Policing Knowledge Hub—the first virtual platform dedicated to fostering police-community cooperation in Ukraine. Developed by the PSP team, this innovative resource will soon be managed by the Community Policing Department of the Patrol Police of Ukraine, ensuring its ongoing development and accessibility.

The Community Policing Knowledge Hub is a free learning platform designed to share best practices, provide safety training for police officers and active citizens, and offer educational materials on safety for both children and adults. It features guidelines for implementing community policing principles, case studies from Ukraine and abroad, and practical tools to strengthen police-community relations.

By making these resources widely available, the platform empowers police officers and local stakeholders to implement effective safety initiatives in their communities. It represents a significant step toward enhancing trust, fostering collaboration, and ensuring a safer future for all Ukrainians.

A Commitment to Safer Communities

The work of the Police Stabilization Project and its partners demonstrates the power of collaboration in addressing local safety challenges. From establishing community safety hubs to launching the Community Policing Knowledge Hub, these initiatives provide critical support during difficult times.

As Ukraine continues to navigate complex security challenges, these efforts offer hope and a strong foundation for the future. By working together, communities and law enforcement can create safer, more inclusive, and resilient environments for all citizens.