Integrity Regime reports

Annual reports cover key milestones and accomplishments for the Government of Canada’s Integrity Regime and demonstrate the department’s ongoing commitment to transparency and open reporting.

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About the Integrity Regime

Introduced in 2015, the Integrity Regime is a government-wide policy-based debarment system designed to ensure the integrity of the Government of Canada’s contracts and real property transactions. It is a key element of the government framework to support accountability and integrity in procurement and real property transactions. The regime aims to:

Public Services and Procurement Canada (PSPC) actively engages with a range of internal and external stakeholders to solicit feedback on key implementation issues, discuss administrative challenges, and to ensure that the regime is well understood and consistently applied. Stakeholder engagement also helps PSPC to identify aspects of the regime that need to be clarified or improved. In addition, PSPC engages with other jurisdictions and non-governmental organizations to share information on the regime, as well as learn from anti-corruption and fraud experts. The department continues to work to further strengthen the accountability and integrity of the Government of Canada’s contracts and real property agreements.

How the Integrity Regime works

The regime consists of:

Through the policy, the government may suspend a supplier, or declare them ineligible, from being awarded a contract or real property agreement with Canada. A determination of ineligibility or suspension is made on the basis of charges and convictions of offences listed in the policy, and relate to white-collar crime such as fraud against Her Majesty, bribery, and collusion.

A supplier who has been charged with an offence listed in the policy may be suspended from receiving contract or real property agreement awards. A supplier who is convicted of an offence, or has an affiliate who is convicted of an offence, listed in the policy, may be declared ineligible for 10 years.

Suppliers that have cooperated with law enforcement authorities, or have undertaken remedial action(s) to address wrongdoing, may enter into an administrative agreement with PSPC either in lieu of suspension, or to reduce their period of ineligibility by up to 5 years. An administrative agreement is an arrangement between the supplier and the government that is used when the department determines it must exercise additional caution to further mitigate risks of contracting with a particular supplier. The agreement includes conditions that the supplier must fulfil to maintain their status to be awarded a federal contract, such as remedial and compliance measures. Additionally, the agreement may include monitoring requirements, at the supplier’s expense, to be conducted by a qualified and independent third party that is recognized by the department.

To further support the policy, directives are occasionally issued to elaborate on or clarify aspects of the policy. Once issued, these directives form a binding part of the policy. Lastly, integrity provisions are included directly in contracts, real property agreements, and related instruments, setting out a supplier’s responsibilities while conducting business with the Government of Canada. The regime applies where the contract or real property agreement has a value greater than $10,000, with some exceptions.

Administering the Integrity Regime

The Integrity Regime is administered centrally by PSPC, and is governed by memoranda of understanding between the department and other federal institutions over a 5-year period. PSPC works actively with federal procurement and real property officers to verify supplier compliance with the regime and assist departments with any issues that arise throughout the verification process. Through integrity verification requests, supplier compliance with the regime is verified prior to contract award to ensure that applicable contracts are not awarded to suppliers which have been charged with or convicted of offences listed in the policy. In most circumstances, integrity verifications requests are submitted through a web-based integrity verification services (IVS) portal and processed through a centralized database within a 4-hour window; 2 hours in urgent situations. In specific cases or crisis situations, emergency verifications can be conducted within a 30-minute service standard, which allows for a temporary fast-track process for events that require contracts be urgently put in place.When a supplier is charged with or convicted of offences linked to unethical business conduct identified under the policy, PSPC assesses this information against the policy’s provisions and may recommend that the Registrar of Ineligibility and Suspension suspend or declare the supplier ineligible to bid or be awarded contracts with the Government of Canada.

PSPC is continuously improving its process for verifying supplier compliance with the regime, as updates are regularly added to the database to ensure it remains robust and current. Additionally, technical enhancements to the IVS portal and database are made regularly to improve client experience, adapt to the evolution of the procurement landscape, and maintain robust security requirements.

PSPC values the ability to measure the operational and organizational effectiveness of the regime. As it stands, the current performance measurement indicators evaluate the volume of verification requests which have been completed within the service standard, as indicated above. The development of additional performance indicators continues to be a priority for the Integrity Regime.

PSPC will aim to continue to deliver a high standard of service excellence, adapting to the Government of Canada’s procurement needs on an ongoing basis.

PSPC remains committed to ensuring the integrity of federal procurement and real property processes and will continue to adapt measures to address emerging challenges.

Years in review

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2022 to 2023

Highlights

  • Overall, a total of 26,289 integrity verification requests were received in 2022 to 2023, representing verifications of 694,020 individual names
  • PSPC received on average 2,191 monthly verification requests and the highest volume was in March 2023 with over 2,789 requests
  • The 2022 to 2023 fiscal year showed a 1.1% increase in integrity verification requests, and an 11.7% increase in individuals verified compared to the previous year, 2021 to 2022
  • 1,023 expedited verification requests were conducted on potential suppliers in the 2022 to 2023 fiscal year
  • Over 99% of these verifications were completed within the program’s 4-hour completion standard
  • 3 companies are ineligible to do business with the Government of Canada due to convictions for a listed offence (Les Entreprises Chatel Inc., R.M. Belanger Limited and Guaranteed Industries Limited)
  • There are 2 active administrative agreements with suppliers (Hickey Construction Ltd. and SNC-Lavalin Group Inc.)
    • the administrative agreement with Hickey Construction Ltd. was established on December 14, 2020 and the administrative agreement with SNC-Lavalin Group Inc. was established on May 11, 2022
    • pursuant to these agreements, both suppliers may continue to do business with the Government of Canada as long as the terms and conditions of the agreements are met

Integrity Regime partners continue to return positive feedback on the verification portal and on the integrity verification client service, and provide further areas for technical development, through the IVS portal user survey.

2021 to 2022

Highlights

  • Overall, a total of 26,000 integrity verification requests were received in 2021 to 2022, representing verifications of 620,815 individual names
  • PSPC received on average 2,176 monthly verification requests and the highest volume was in December 2021 with over 2,613 requests
  • The 2021 to 2022 fiscal year showed a 2.2% increase in integrity verification requests, and a 33% increase in individuals verified compared to the previous year, 2020 to 2021
  • 1,078 expedited verification requests were conducted on potential suppliers in the 2021 to 2022 fiscal year
    • over 99% of these verifications were completed within the program’s 4-hour completion standard
  • 3 companies are ineligible to do business with the Government of Canada due to convictions for a listed offence (Les Entreprises Chatel Inc., R.M. Belanger Limited and Guaranteed Industries Limited)
  • There is 1 active administrative agreement with a supplier (Hickey Construction Ltd.)
    • this administrative agreement was established on December 14, 2020 and pursuant to the agreement, the supplier may continue to do business with the Government of Canada as long as the terms and conditions of the agreement are met

To measure client satisfaction, PSPC conducted the IVS portal user survey which was responded by 1,112 procurement and real property officers. Through the survey, the majority of procurement officers indicated that they are satisfied with the service received and the response time of the Integrity Regime Team. Regarding the IVS portal, 88.26% of responses from procurement officers stated that the portal was easy to navigate and 68.62% of respondents responded that there were no areas that required improvement.

2020 to 2021

Highlights

  • 619 expedited verification requests were conducted on potential suppliers in the 2020 to 2021 fiscal year
  • Overall, a total of 25,447 integrity verification requests were received in 2020 to 2021, representing verifications of 467,575 individual names
  • The average number of monthly verification requests was approximately 2,050
  • The 2020 to 2021 fiscal year showed a 12% decrease in integrity verification requests, but a 25% increase in individuals verified compared to the previous year, 2019 to 2020
  • Over 99% of these verifications were completed within the program’s 4-hour completion standard
    • to date, no contracts have been awarded to a supplier that is ineligible or suspended under the Integrity Regime
  • Currently, under the regime, 3 companies (Les Entreprises Chatel Inc., R.M. Belanger Limited and Guaranteed Industries Limited) are ineligible to do business with the Government of Canada due to convictions for a listed offence
  • Hickey Construction Limited may do business with the Government of Canada pursuant to an administrative agreement which came into effect on December 14, 2020
    • an administrative agreement between the Government of Canada and SNC-Lavalin Group Inc. concluded in December 2020 following the final disposition of criminal charges facing the supplier

In support of the Government of Canada’s response to the pandemic, including securing necessary products and supplies for Canadians, PSPC continued to provide an excellent response time on integrity verification requests, ensuring minimal disruption to clients’ procurement and real property processes.

2019 to 2020

Highlights

  • 20 expedited verification requests were conducted on potential suppliers in the 2019 to 2020 fiscal year
  • Overall, a total of 28,933 integrity verification requests were received this year, representing verifications of 374,413 individual names
  • Over 99% of these verifications were completed within the program’s 4-hour completion standard
  • PSPC received on average 2,355 monthly verification requests, and the highest volume received was in November 2019 with over 4,600 requests
  • Overall, the 2019 to 2020 fiscal year showed an 8.17% increase in integrity verifications and an 8.9% increase in individuals verified over the previous year
    • 3 companies were ineligible from doing business with the Government of Canada, while 1 company held an administrative agreement with PSPC in lieu of suspension

The 2019 to 2020 fiscal year presented a fast-paced and constantly evolving marketplace in the context of the COVID-19 pandemic. To support the Government of Canada’s response to the pandemic, including securing necessary products and supplies for Canadians, the Integrity Regime created a process to expedite urgent pandemic-related integrity verifications.

Integrity Regime partners continue to return positive feedback on the verification portal and on the integrity verification client service, and provide further areas for technical development, through the IVS portal user survey. In 2019 to 2020 a survey of over 4,000 procurement officers was conducted and the majority of procurement officers indicated that they were satisfied with the service received and the response time.

Any questions regarding the Integrity Regime, can be sent to the generic email inbox: pwgsc.o.integrity-tpsgc.o.integrite@pwgsc-tpsgc.gc.ca.

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