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 PROTECT2 project, funded by Canada’s Department of National Defence, is a vital initiative responding to the Ukrainian government’s defence and security priorities. By deploying Ukrainian expertise, the project supports sustainable, accountable, and democratic reform within the country’s armed forces. A key focus of PROTECT2 is fostering gender equality and ensuring women’s active participation in military leadership. Inna Zavorotko Is one such woman, exemplify this mission through her tireless dedication to gender advocacy and support for Ukraine’s servicewomen.

Inna Zavorotko: A Life Dedicated to Service and Advocacy

From an early age, Inna Zavorotko dreamt of becoming a military lawyer. Her passion for justice and determination to improve military systems through the power of law guided her career. Currently, Inna, a Lieutenant Colonel of Justice of the Armed Forces of Ukraine, serves as the Deputy Head of the Section of International Law at the Legal Department of the Ministry of Defence of Ukraine.

In her role, Inna oversees the implementation, enforcement, and dissemination of International Humanitarian Law within Ukraine’s Armed Forces. Her mission is to align military practices with international legal standards, ensuring compliance during times of war.

Her dedication extends far beyond her office. Inna participated in the Joint Forces Operation in Donbas. She later became a peacekeeper serving as part of Ukraine’s national personnel in the United Nations Mission in the Democratic Republic of Congo.

Through the lens of international humanitarian law, Inna brings attention to gender-based crimes committed by Russian forces by amplifying these issues on the global stage and advocating for justice. At the same time, understanding the importance of equipping Ukrainian military personnel with practical tools, Inna supported the creation of the Soldier’s Card on Communication with CRSV Survivors. This resource is a guide on how to interact with survivors with empathy, respect, and care. The card emphasizes active listening, discourages victim-blaming, and directs survivors to national services for support. It has become a powerful tool in training members of the Armed Forces of Ukraine on handling this highly sensitive issue.

Inna’s work stands as a testament to her passion to law, and deep commitment to ensuring that international principles is everyday realities within Ukraine’s Armed Forces.

ChangeMakers: Highlighting the Women Leading Transformation

Inspiring women joined Ukraine’s military at the onset of war, driven by a shared commitment to service and gender equality. Their stories are part of ChangeMakers, an innovative photography exhibit highlighting the work of gender advisors, gender focal points, and human security policymakers within the Ukrainian Armed Forces.

ChangeMakers aligns Ukraine’s Women, Peace, and Security policies with NATO standards, empowering leaders like Inna Zavorotko to drive transformative change. Through this initiative, these trailblazers share their insights, experiences, and vision for Ukraine’s future—one where gender equality strengthens national security and ensures a more resilient and inclusive defence sector. Explore the PROTECT2 projects and other women featured in the ChangeMakers photography initiative here: Changemakers Portraits – PROTECT2.