5.16. Integrity compliance

Attention! As the transition to CanadaBuys is ongoing, Supply Manual references to ABE are to be interpreted as a generic system reference only. Users of the SAP Ariba environment should adapt their activities accordingly.

Buyers are advised to consult the tools available on CanadaBuys for guidance and procedures on completing procurement transactions in the SAP Ariba environment.

  1. Before awarding a contract (including issuing a purchase order), issuing a standing offer (SO) or supply arrangement (SA), or publishing of a pre-qualified supplier list, contracting officers must first verify with the Registrar of ineligibility and suspension (the Registrar) that the bidder, offeror or supplier is not ineligible to be awarded a contract or suspended. Certain charges, convictions and other circumstances, as described in the Ineligibility and Suspension Policy will or may render the bidder, offeror or supplier ineligible to be awarded or suspended from being awarded a contract.
  2. The integrity verification process with the Registrar is not required in the following circumstances:
    1. call-ups against standing offers;
    2. contracts against supply arrangements (SAs) (note: an integrity verification is typically not required when awarding a contract against an SA, however an integrity verification will be required when awarding a contract against an SA issued prior to April 4, 2016, where the latest Integrity Provisions have been incorporated by reference into the solicitation);
    3. task authorizations;
    4. contract amendments unless there is a change to the Integrity Provisions or members of the board of directors;
    5. purchases using acquisition cards;
    6. contracts where the transaction value is less than $10,000.00 (GST/HST included) (see the Policy for definition of transaction value); or
    7. any other contract or type of contract specified in Section 4.b) of the Policy or directive issued further to the Policy.
  3. Verification process:
    1. Before awarding a contract (including issuing a purchase order with a transaction value of $10,000 or more, including GST/HST), issuing an SO or an SA, or publishing a pre-qualified supplier list, contracting officers must submit the information on the bidder, offeror or supplier to the Registrar using the Integrity Database Services (IDS) portal.
    2. Responses are typically provided within 4 hours for routine requests and within 2 hours for urgent requests, on business days, between 8:00 a.m. and 4:00 p.m. Eastern Standard Time.
    3. List of directors or corporate owners:
      1. Contracting officers are not required to verify whether bidders, offerors or suppliers should have provided a list of directors or corporate owners, but are simply to submit to the Registrar the information as received from the bidders, offerors or suppliers.
      2. Where a bidder, offeror or supplier has not provided a list of directors or corporate owners with their bid, offer or arrangement, the contracting officer must submit the complete legal name, address and Procurement Business Number (PBN) of the successful bidder, offeror or supplier, along with the solicitation number (or proposed contract number) to the Registrar.
      3. The Registrar determines whether a bidder, offeror or supplier should have provided a list of directors or corporate owners. In the event that such list should have been provided, the Registrar will communicate this requirement to the contracting officer, who will then inform the bidder, offeror or supplier of their obligation to provide the list within a recommended 10 business days. Failure to provide this information within the timeframe stipulated by the contracting officer will render the bid , offer or arrangement non-responsive. See 5.5.5 Certifications, declarations and proofs.
    4. Verification responses:
      Three responses are possible, as described below. Contracting officers are to keep a copy of the confirmation e-mail from the Registrar in the procurement file. This process and the estimated timelines can be delayed should additional information be required by IDS to allow them to make a determination.
      1. "Integrity result – The supplier is not ineligible. (No match)": This response confirms that the contracting officer may award the contract, issue the standing offer or the supply arrangement, or publish the list of pre-qualified suppliers.
      2. "Ineligibility confirmed": This response indicates that the bidder, offeror, or supplier has been determined to be ineligible or suspended as per the Ineligibility and Suspension Policy. The bidder, offeror or supplier is suspended or ineligible to be awarded a contract or issued a standing offer or supply arrangement, or to be included in a list of pre-qualified suppliers. In exceptional circumstances, the contracting officer may request a Public Interest Exception (PIE) to enter into a contract with an ineligible supplier.
      1. "Caution due diligence should be applied": This response advises that the bidder, offeror or supplier is not ineligible. However, the level of delegation to enter into the transaction has been raised to Assistant Deputy Minister or Director General as indicated in the verification response email. This information is for internal discussion and decision making only and, as such, should never be discussed with external parties.
    5. Where “Ineligibility confirmed” or “Caution due diligence should be applied” responses are received, contracting officers must consult with the Acquisitions Program Integrity Secretariat (APIS) by e-mail at TPSGC.DGAIntegrite-ABIntegrity.PWGSC@tpsgc-pwgsc.gc.ca, and obtain the required approval as stipulated in Annex 6.4.1. Approval Authorities and Additional Signing Authorities in Support of Clients' Programs Only – Other than for Canadian Commercial Corporation.
    6. Where the Registrar must confirm the identity of an individual as a result of an integrity verification response, they will request information directly from the individual in question.
  4. Verification Process for Amendments:
    1. Contracting officers must propose the latest general conditions, which include the most recent Integrity Provisions when amending a contract as per section 4.21 Integrity Provisions, subsection d. The verification process as outlined in subsection c. above must be followed if the contractor accepts the new Integrity Provisions to be included in the contract amendments, and the existing contract contains Integrity Provisions dated prior to July 2015.
    2. The verification process as outlined in subsection c. above must be followed for contract amendments where the file does not already contain a record of a previous verification.
    3. If a previous verification was performed and the results are on file and the Integrity Provisions have not changed, no further action is necessary.
  5. If a contractor is found to be ineligible or is suspended while the contract is active, the Registrar will contact the contracting officer who requested the integrity verification for that particular contract. The contracting officer, with the assistance of the Acquisitions Program Integrity Secretariat (APIS), will determine whether the contract can be terminated for default. If the contract is to be terminated for default, APIS will assist the contracting officer. The ineligible or suspended contractor may be required to enter into an Administrative Agreement with Public Works and Government Services Canada if the contract is not terminated.
  6. Awareness and Prevention: Before contract award or issuance of standing offers or supply arrangements, the successful bid or offer must be reviewed by a contracting officer who has completed the training on Bid Rigging Awareness and Prevention. This can be the same contracting officer assigned to the procurement file.
  7. For further details on Integrity, see the following sections:
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