Accountability

Accountability is the obligation of an organization or a person to explain, justify and take responsibility for decisions, actions and the use of resources. In public procurement, it means that responsibility for each part of the process is clearly assigned and can be audited, and that public funds are managed with care.

The term appears across Canadian federal procurement guidance and in the procurement rules of NATO. Both link accountability with transparency, integrity, good governance, auditability and value for money. For suppliers, the practical question is who answers for what: the contracting authority, the department that needs the goods or services, and the supplier that signs the contract.

How Canadian federal procurement divides accountability

CanadaBuys states that Public Services and Procurement Canada (PSPC) is accountable for the integrity of the contracting process. The process must be open, fair and transparent. Client departments carry a different responsibility: they must provide complete and accurate information about their requirements. The guiding principles of procurement set out this split.

The effect is that accountability for the requirement sits with the client, while accountability for running a sound contracting process sits with PSPC. A vague or incomplete requirement is a client responsibility, not a supplier one.

The challenge function across the procurement life cycle

PSPC exercises a challenge function throughout the procurement life cycle. According to the responsibilities matrix between PSPC and clients, its purpose is to ensure compliance with applicable statutes, regulations, agreements, policies, directives, procedures and guidelines.

In practice, this means PSPC can question how a requirement is described or how a procurement is structured before a solicitation reaches the market.

Supplier obligations under federal ethical standards

Accountability also runs toward suppliers. The Treasury Board Directive on the Management of Procurement requires suppliers and subcontracted suppliers to apply ethical and sustainability standards across their supply chains and to adhere to the Code of Conduct for Procurement.

Shared Services Canada (SSC) sets out similar expectations in its standard on ethical behaviour in procurement and contracting. SSC contracts must include provisions addressing:

• contingency fees
• supplier declarations concerning certain Criminal Code offences
• corruption
• collusion, bid-rigging and other anti-competitive conduct

A false declaration or non-compliance with these provisions can constitute a contract default.

Accountability in NATO common-funded procurement

NATO states that it is accountable to member governments and taxpayers for the financial resources provided to operate the organization. Its transparency and accountability framework includes the NATO Financial Regulations, corporate-governance guidelines and the NATO Accounting Framework. The International Board of Auditors provides assurance that joint and common funds are used properly, and it performs both financial and performance audits.

NATO's Procurement Policy for Common Funding requires high standards of integrity and accountability, value for money and effective stewardship of public funds. It also states that procurement authorities are responsible and accountable for the timely and efficient procurement of required goods, works and services. The NATO procurement manual adds that procurement involves the use of, and accountability for, member funds, which makes transparency essential.

What accountability means for a supplier bidding on Canadian public contracts

The cited Canadian sources place primary institutional accountability on contracting authorities and client departments. Suppliers are accountable for compliance with the ethical, sustainability, disclosure and anti-corruption clauses written into the solicitation or contract.

• Read the integrity and ethical-behaviour provisions in each solicitation and treat every declaration as a binding statement.
• Apply the Code of Conduct for Procurement to your subcontractors as well as to your own firm.
• Keep records that show how your bid and your performance meet the stated requirements, since the process is built to be auditable.