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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Public investment in Ukraine was a central topic at the 2025 Ukraine Recovery Conference in Rome, which brought together the global community united behind Ukraine and the country’s future.

“I would like to emphasize that a key condition for the effective implementation of public investment reform is the work on updating strategies,” said Oleksii Sobolev, First Deputy Minister of Economy of Ukraine.

“In this context, we are especially grateful to the Government of Canada and the Recovery for All Project for their support in developing the ProjectUA system. This system is designed to consolidate strategies, promote a unified strategic vision, and – together with platforms like DREAM, serve as part of the digital foundation of the reform,” continued Mr. Sobolev, referencing DREAM, which is a digital ecosystem acting as a single window for public investment projects and programs.

Presenting ProjectUA

Tawnia Sanford Ammar, Alinea’s Country Director for Ukraine and Field Director for Recovery for All.

Funded by Global Affairs Canada, ProjectUA is a tool delivered by the Recovery for All Project, serving as part of a digital foundation for reform by:

Building a unified strategic vision for managing public investments.
Setting priorities based on real needs, in line with strategic documents.
Tracking implementation progress and results, while ensuring transparency and government accountability.
Accessing data on progress toward strategic goals, as well as on Ukraine’s commitments to international partners, including the EU.

This year’s conference featured a session about how ProjectUA enhances strategic planning. Tawnia Sanford Ammar, Alinea’s Country Director for Ukraine and Field Director for Recovery for All, delivered a presentation at the Business Fair Stage covering how this system unites all Ukrainian strategies and plans into one single policy agenda.

“ProjectUA is a database of Ukrainian plans and strategies with a powerful suite of project management tools,” said Ms. Sanford Ammar.

“We are able to take all of the plans and look at where there are overlaps between the plans and the strategies, especially in terms of indicators and data that will be collected to report on those indicators. This makes reporting comprehensive and cohesive, and solves the problem of having various ministries report on the same data in different ways.”

Video: How ProjectUA works

Funded by Global Affairs Canada, Recovery for All delivers locally driven, inclusive and gender responsive recovery in Ukraine. Learn more about the challenges addressed by ProjectUA and how the system works by visiting the RFA YouTube channel – video available in both Ukrainian and English.