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.
On June 21 and 22, the international community convened for the Ukraine Recovery Conference in London. Launched in 2017 as the Ukraine Reform Conference, this year’s edition held jointly by the UK and Ukraine focused on mobilizing international support for Ukraine’s economic and social stabilization and recovery from the effects of war.
Oleksandr Kubrakov, Ukraine’s Deputy Prime Minister for Restoration
Against the backdrop of the conference, Alinea supported the Government of Ukraine on the side event, Sustainable Inclusive Recovery: Fostering Community Capacity to Meet Local Needs.
He went on to explain why building the capacity of this level of government to develop restoration plans is critical, which his Ministry recognized and implemented when regional policy became part of his scope.
Deputy Prime Minister Kubrakov’s keynote address launched an afternoon of expert insights into community-led recovery. In addition to nearly 200 people in attendance, more than 6,500 tuned in to the online broadcast – streamed in both Ukrainian and English and available here.
This session explored how to help communities recover while respecting decentralized governance. Moderated by Charles Duff, Alinea Vice President and Managing Director, panel discussions covered what it means to undertake and achieve an inclusive, sustainable recovery.
“We see engagement with local governments and civil society, as well as the participation of women, as key to Ukraine’s recovery and reconstruction,” said Sandra McCardell, Assistant Deputy Minister for Europe, Arctic, Middle East and Maghreb Branch of Global Affairs Canada.
Sandra McCardell, Global Affairs Canada
Speakers and participants weighed-in on how the Government of Ukraine can ensure recovery works for everyone, and that revitalization considers the impact of today’s choices on future generations. Panelists included representatives from different levels of government, local governance associations, and civil society organizations – all working to establish effective cooperation for the efficient recovery and development of communities and territories of Ukraine.
“Inclusion is key to recovery. It is through inclusion that we can build a lot of components so we can make sure we bring people back to Ukraine,” said Oleksandr Vorona, President of Kyiv Municipal League of Public Organizations of People with Disabilities.
Mr. Vorona spoke on the “Voices of Communities” panel, moderated by Oleksandr Solontay, CEO of the NGO Agency for Recovery and Development – a project with the EU Anti-Corruption Initiative for an efficient recovery. Mr. Solontay also serves as the Senior Decentralization Advisor for the Support to Ukraine’s Reforms for Governance (SURGe) Program, funded by Global Affairs Canada and implemented by Alinea. A key partner to the Government of Ukraine and on this event, the SURGe Program helps the Government to design and deliver governance and economic reforms, as well as improve management of the national reform agenda.
Tawnia Sanford Ammar, SURGe Project Director
“Recovery has to be a comprehensive recovery,” said Tawnia Sanford Ammar, SURGe Project Director. “We have to build back better, not only in terms of infrastructure, but in terms of social and economic development, governance, and anti-corruption measures.”
As part of the event’s concluding panel, SURGe Project Deputy Director Iryna Tushnytska spoke to Ukraine’s key governance reforms achieved before the war and why maintaining this momentum matters.
“We have the unique window of opportunity now to continue reforms that have been started in many areas like medical, administrative services, education, and others,” said Ms. Tushnytska.
“We have the opportunity and the call from society to continue these reforms.”
Alinea team pictured with Ukraine’s Deputy Prime Minister for Restoration, left to right: Iryna Tushnytska, SURGe Project Deputy Director; Bob Francis, Alinea President & CEO; Oleksandr Kubrakov, Ukraine’s Deputy Prime Minister for Restoration; Tawnia Sanford Ammar, SURGe Project Director; Charles Duff, Alinea Vice-President & Managing Director
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