Integrity

Integrity is the link between behaviour and principles. NATO uses that wording in its Building Integrity policy and ties institutional integrity directly to good governance. In procurement, the term describes whether the people, processes and organisations involved act honestly, competently and accountably. See the NATO Building Integrity policy.

In Canadian federal procurement, integrity also has a specific operating meaning: the Government of Canada's Integrity Regime. It was introduced in 2015 so that Canada does business only with ethical suppliers, and it generally applies to federal procurement and real-property transactions over $10,000, as described in the National Defence procurement overview. Public Services and Procurement Canada (PSPC) administers it.

How NATO describes integrity in people, processes and organisations

NATO's Building Integrity materials apply the term at three levels. An individual has integrity when they do their work competently, honestly and completely. A process has integrity when it works as intended within the larger system of which it is part. An organisation has integrity when it operates accountably and competently, without diverting resources to corrupt or dishonest ends. These descriptions appear in the NATO Building Integrity self-assessment handbook.

NATO applies the same standard to buying. Its procurement policy requires procurement to conform to the highest standards of integrity and accountability, and it states that there is no tolerance for fraud and corruption. Related NATO terms include transparency, accountability, good governance, fraud and corruption.

The three components of the Canadian Integrity Regime

The federal regime has three parts that work together:

• The Ineligibility and Suspension Policy, which sets out when a supplier may be declared ineligible or suspended.
• Integrity directives, which instruct federal departments and agencies on how to apply the regime.
• Integrity provisions, which write the regime into solicitations, contracts and real-property agreements.

Because of these provisions, the regime appears in competitive solicitations, contracts, purchase orders, standing offers, supply arrangements, pre-qualified supplier lists and related real-property transactions. PSPC publishes the policy and directives under its supplier integrity and compliance pages.

Eligibility checks before award

Contracting officers must verify an offeror's status before they act. Before awarding a contract, issuing a purchase order, standing offer or supply arrangement, or publishing a pre-qualified supplier list, they confirm the offeror is not ineligible or suspended in the Registrar of Ineligibility and Suspension. The CanadaBuys buyer's guide lists this among the elements to consider at award.

The regime also reaches contract takeovers. Where a supplier defaults and a surety, replacement entity or completing contractor assumes responsibility for the work, the regime can apply to that entity and its relevant first-tier subcontractors. PSPC sets this out in its directive on the application of the regime to replacement entities and completing contractors.

The $10,000 threshold

Contracts, subcontracts and real-property transactions below $10,000 are excluded from the Integrity Regime under PSPC's directive. Procurement and real-property authorities do not perform an integrity verification for those transactions, and suppliers do not perform one for subcontracts below that value. The exclusion is set out in the directive on awarding contracts and real-property transactions below $10,000.

What integrity means for a supplier bidding on Canadian public contracts

For a supplier, integrity is a condition of getting federal business. Suppliers must comply with the applicable integrity requirements in a solicitation or contract. A supplier found ineligible or suspended can be prevented from receiving federal awards, and eligibility is checked before award, not after. Bid teams should treat the integrity provisions in each solicitation as binding terms and confirm them before submitting. Suppliers who step in to complete another supplier's work, and their first-tier subcontractors, can also fall under the regime.