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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For over three years, Ukrainian women police officers have been on the front lines, working tirelessly to protect civilians, uphold law and order, and ensure public safety in communities across the country. Their dedication and resilience are crucial in maintaining stability during these challenging times. Their presence in law enforcement has not only strengthened the security sector but has also paved the way for greater gender inclusivity within traditionally male-dominated professions.

Alinea International’s Police Stabilization Project (PSP) stands in solidarity with Ukrainian women in their pursuit of gender equality and leadership roles, particularly within law enforcement and we are eager to highlight their contributions this International Women’s Day. PSP remains committed to fostering an inclusive security sector that empowers women leaders and strengthens gender-responsive policing. By equipping women officers with training, resources, and support networks, PSP is building a more effective and representative police force that serves all members of society.

Since 2018, with the support of Global Affairs Canada, PSP has maintained a strong partnership with the Ukrainian Association of Women in Law Enforcement (UAWLE). This collaboration has provided a platform for advocacy, professional development, and networking, helping to amplify the voices of women in the security sector. By continuously supporting UAWLE, PSP advances the integration of gender equality within Ukraine’s law enforcement institutions. This partnership not only elevates women within the police service but also strengthens institutional frameworks that support gender equality and accountability.

To ensure the safety of women and girls in communities across Ukraine, PSP fosters collaboration between police forces and civil society while supporting safety hubs in various regions. These initiatives have proven effective in preventing domestic violence, assisting survivors of conflict-related sexual violence, and addressing emerging security challenges in conflict-affected areas. By working with community organizations, law enforcement can build trust and establish protective measures that directly benefit those most vulnerable to violence and exploitation.

Gender equality is a cornerstone of sustainable peace, security, and recovery. The 2025 International Women’s Day theme “For ALL Women and Girls: Rights. Equality. Empowerment” provides us with an opportunity to underscore the need for action to unlock equal rights, power, and opportunities for all, envisioning a feminist future where no one is left behind. A crucial part of this vision is empowering the next generation—youth, particularly young women and adolescent girls—as key drivers of lasting change. When young women are given leadership opportunities, they shape policies and practices that reflect their realities, ensuring a more inclusive and just society for future generations. As the conflict continues to evolve, PSP’s work remains critical in supporting a resilient police force that upholds human rights and fosters community trust.

With a strong emphasis on rights-based policing, PSP integrates inclusive policing principles and advances policies aligned with international human rights standards, such as the Istanbul Convention and the Universal Declaration of Human Rights. By strengthening law enforcement’s ability to respond to gender-based violence and ensuring accountability within the police force, PSP is creating long-term, systemic change that will continue to benefit Ukrainian society beyond the immediate crisis.

As we celebrate International Women’s Day, PSP reaffirms its commitment to advancing gender equality in law enforcement and beyond. By strengthening the role of women in policing, ensuring their voices are heard, and equipping them with the tools to lead, PSP is contributing to a more just and secure future for all. This March 8, we honor the courage and dedication of Ukrainian women in law enforcement and renew our pledge to support their fight for equal rights, security, and empowerment. The role of women in law enforcement remains integral to building a safer, more inclusive future for all Ukrainians on their path toward recovery and resilience.