Integrity Compliance

Integrity compliance is a supplier's compliance with the Government of Canada's requirements for ethical and eligible participation in federal contracting and real-property transactions. These requirements are administered through the Office of Supplier Integrity and Compliance (OSIC) at Public Services and Procurement Canada (PSPC) and through the Ineligibility and Suspension Policy.

The policy allows the government to identify suppliers of concern and take action to reduce the risks they pose. Federal sources use the phrases "supplier integrity and compliance" and "integrity compliance" for this work. Its purpose, as PSPC describes it, is to promote ethical business practices in federal procurement. PSPC's overview of supplier integrity and compliance sets out the program.

How the Ineligibility and Suspension Policy works

Integrity compliance sits within the federal Integrity Regime, a government-wide, policy-based system. Under the regime, a supplier can be declared ineligible or suspended from doing business with the Government of Canada. PSPC runs the program through OSIC.

The requirements reach suppliers through contract documents. The Ineligibility and Suspension Policy is incorporated into solicitations, resulting contracts and real-property agreements through policy clauses. A supplier that bids on or accepts a federal contract is therefore bound by these terms.

Integrity verification and declaration forms

PSPC verifies supplier compliance before it awards a contract or real-property agreement. It does this through integrity verification requests. Suppliers must submit the information required for verification with their bids and offers, and they must update that information as the policy requires. The supplier guidance explains these obligations.

A supplier that cannot certify compliance must submit an Integrity declaration form with its bid or offer. The PSPC forms page lists the Integrity declaration form and the other forms used under the policy.

Subcontractor eligibility under the policy

Integrity compliance extends below the prime contractor. Prime contractors must verify the eligibility of certain first-tier subcontractors before bid submission and before entering into a direct contractual relationship with them. A prime contractor that wants to use a subcontractor that is suspended or ineligible must submit a Subcontractor exception form. Both requirements appear on the forms page.

Integrity requirements beyond PSPC

Other federal organizations apply their own integrity instruments. Defence Construction Canada (DCC) applies a Procurement Code of Conduct and an Integrity Management Framework to suppliers that submit offers, may submit offers, or have been awarded DCC contracts. DCC publishes its Procurement Code of Conduct and its Integrity Management Framework for industry.

Federal procurement policy also requires procurement organizations to maintain process integrity. It requires suppliers and subcontracted suppliers to observe ethical standards and the Code of Conduct for Procurement, as set out in a Treasury Board Secretariat publication.

What integrity compliance means for a supplier bidding on Canadian public contracts

For a bid team, integrity compliance is a set of practical tasks that run from bid submission through contract performance:

• Complete required certifications and disclosure forms accurately.
• Provide the names and information needed for integrity verification, and keep that information current.
• Submit an Integrity declaration form if you cannot certify compliance.
• Confirm that relevant first-tier subcontractors are eligible before you bid, and file a Subcontractor exception form where one is needed.
• Disclose conflicts and any other required information.
• Comply with the applicable integrity clauses throughout the procurement and the contract period.

Build these checks into your bid process early. A missed form or an ineligible subcontractor can stop an award at the verification stage.