PWGSC's Integrity Framework

PWGSC has a strong framework in place to support accountability and integrity in its procurement and real property transactions. This includes policies, procedures and governance measures to ensure fairness, openness and transparency. Over time, the department has put in place numerous measures that demonstrate its commitment to doing business with companies and individuals that respect the law and act with integrity.

The table below outlines the key elements of PWGSC's Integrity Framework, including how, when and to whom it applies.

Integrity Framework Overview

Types of contracts covered

The Integrity Framework applies only to PWGSC managed contracts and real property transactions. This includes:

  • construction contracts;
  • goods and services contracts (from office supplies, to military ships, to security systems, and everything in between); and
  • real property transactions (leasing agreements, letting of space and the acquisition and disposal of Crown-owned properties).
Dollar value of contracts covered

There is no dollar threshold. The Integrity Framework applies to all PWGSC-managed contracts and real property transactions.

Offences covered

A bidder1 would be ineligible to do business with PWGSC following a conviction2 under any of the following offence:

  • frauds against the government under the Criminal Code of Canada;
  • frauds under the Financial Administration Act;
  • payment of a contingency fee to a person to whom the Lobbying Act applies;
  • corruption, collusion, bid-rigging or any other anti-competitive activity under the Competition Act;
  • money laundering;
  • participation in activities of criminal organizations;
  • income and excise tax evasion;
  • bribing a foreign public official; and
  • offences in relation to drug trafficking.
Discretionary provisions

PWGSC's Integrity Framework is conviction-based and does not include discretionary provisions.

Applicability to sub-contractors / sublessors

PWGSC does not apply its integrity framework to sub-contractors. Its relationship is with the prime contractor.

However, some contracts stipulate that the contractor agrees to bind the subcontractor by the same conditions by which the contractor is bound under the contract.

Time limitation

There is no time limit on the ineligibility of convicted bidders.


Convicted bidders will remain ineligible unless:

  • they have received a pardon (record suspension); or
  • their capacities were restored by the Governor in Council.

The Public Interest Exception

  • applies in circumstances in which it is necessary to the public interest to enter into business with a bidder that has one of the convictions listed under PWGSC's integrity framework.

Possible circumstances necessary to the public interest could include:

  • only one person or company is capable of performing the contract;
  • emergency;
  • national security;
  • health and safety; and
  • economic harm.

The exception is applied on a case-by case basis by PWGSC.

In such cases, PWGSC would also impose additional stringent controls, administrative measures, and monitoring in the contract or real property agreement.

Recourse in the event of a conviction post contract award

PWGSC may terminate a contract or real property agreement for default if a conviction occurs post contract award, or may continue with the option and impose enhanced oversight and monitoring measures.

List of ineligible bidders

PWGSC does not maintain a list of ineligible bidders.

  • With the submission of their bid, the bidders certify that they do not have any of the convictions listed under PWGSC's Integrity Framework.
  • PWGSC verifies the eligibility of the winning bidder and authorizes it for the specific competitive process.
  • Certification and verification are done for each bid.

Bidder 1: An individual or company seeking to do business with the Government of Canada.

Convictions 2: The Integrity Framework applies to convictions of the bidder as well as anyone, individual or other entity, who directly or indirectly, legally or de facto, controls the company. This includes any affiliates and members of the board of directors.

For further information on integrity provisions for procurement, visit:

To find out more about integrity clauses for real property transactions, consult: