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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Advancing Women’s Economic Autonomy

In line with its commitment to gender equality and the empowerment of women, youth, and Indigenous populations in vulnerable situations, the Women Leading Change (MLC) project has successfully implemented two key economic empowerment programs across the Dry Corridor of Honduras, El Salvador, and Guatemala:

The Trinational Economic Empowerment Program “Entrepreneurial and Inclusive Municipality (MEI)”
The Business Mentorship Program “Women Empowering Women”

These initiatives are designed to provide practical tools and comprehensive training to women—particularly survivors of sexual and gender-based violence. It equips them with the skills needed to launch or strengthen their businesses and progress toward economic autonomy.

Implementation on the Field

Both programs were developed during the project’s second year and launched in their first phase between July and November 2024 in:

El Salvador: Candelaria de la Frontera, Cítala, Dulce Nombre de María, and San Francisco Morazán
Honduras: Ocotepeque, Sinuapa, San Marcos, and La Labor
Guatemala: Camotán, San Juan Ermita, Santa Catarina Mita, and Asunción Mita

A second phase followed from January to April 2025, with adaptations in El Salvador reflecting the new administrative divisions that came into effect in June 2024. This included the integration of new districts such as Nueva Concepción and Tejutla into larger municipalities like Chalatenango Centro and Santa Ana Oeste.

The Women Empowering Women mentorship program was also implemented in two editions:

First edition: May–August 2024 in Honduras and El Salvador, and October–December 2024 in Guatemala
Second edition: December 2024–April 2025 in Guatemala, and March–May 2025 in Honduras and El Salvador

Tackling Structural Gender Barriers

These programs directly address the systemic gender barriers that limit women’s economic participation through an integrated approach that includes:

Building self-esteem and assertiveness
Developing entrepreneurial competencies
Providing technical support and personalized mentorship

Results to Date

So far, 827 women have successfully completed training under both programs. In addition, 808 women entrepreneurs have received productive equipment to support their businesses:

264 in Guatemala
263 in El Salvador
281 in Honduras

Strategic Partnerships

The sustainability and scalability of these initiatives have been made possible through partnerships with key local and national institutions, including:

Municipal governments and Women’s Offices in the 12 project intervention areas
Cayaguanca Municipal Association: Facilitated the first MEI edition in El Salvador and Honduras
CONAMYPE (National Commission for Micro and Small Enterprises): Implemented the second MEI edition and currently leads the second phase of technical support in El Salvador
CDE MIPYME Region Lempa (Business Development Center): Leads the second edition and ongoing technical support phase in Honduras
INTECAP (Technical Institute for Training and Productivity): Will lead specialized training for the second training phase in Guatemala

These collaborations have been essential in amplifying the project’s impact and ensuring its long-term sustainability at both local and regional levels. Together, they are helping build a more inclusive, resilient, and equitable future for women entrepreneurs in Central America.