Communiqué – Proactively addressing conflicts of interest: A mandatory requirement of the Code of Conduct

Dear suppliers,

We know that the majority of our suppliers uphold the highest standards when contracting with Canada. However, Public Services and Procurement Canada's (PSPC) mandate inherently carries higher risks associated with conflicts of interest (COI). Ensuring respect for and adherence to the Code of Conduct for Procurement (the Code) is of utmost importance and we wish to remind suppliers of their obligations under the Code, which is integral to all Government of Canada procurement activities.

It is crucial to steer clear of any situations that might present a COI. By contracting with Canada, you are warranting that no real, apparent, or perceived COI exists or is likely to arise in the performance of the contract. This includes situations where shareholders, directors, associates or close relatives of a supplier are employed within the Public Service. If you become aware of any matter that causes or may cause a COI, it must be disclosed to the contracting authority in writing. This allows Canada to conduct a proper assessment and ensure the integrity of the procurement process.

For example, it is imperative for a supplier to avoid any participation in the drafting of the Statements of Work (SOWs) that could influence procurement processes unfairly. In addition, when responding to bid solicitations, requests for standing offers or supply arrangements, or requests for task authorization proposals, it is necessary that submissions accurately reflect your company’s capacity to satisfy the stipulated requirements. This includes documenting that you have the permission of resources or sub-contractors you are proposing to perform work and that you have carried out quality assurance to validate these resources or sub-contractors are accurately represented.

PSPC will work with suppliers to address potential instances of non-compliance with the Code, and ensure a sound understanding of expectations in order to address any apparent lack of compliance. If suppliers or their sub-contractors are unable or unwilling to comply with the Code, PSPC reserves the right to take appropriate actions including but not limited to seeking more information, deeming a bid non-responsive, terminating the contract for default, setting aside the standing offer, issuing a stop work order, or suspending or cancelling the supply arrangement.

PSPC’s goal is not just to maintain, but to elevate the standards governing procurement by fostering an environment of fairness and transparency. Our collective ability to deliver results for Canadians while upholding the principles that define us must remain at the forefront of belief.

If you have questions or wish to disclose a situation that could lead to a potential conflict of interests, please contact the contracting authority responsible for the contract at issue, or send an email to tpsgc.sacengagementpacengagement.pwgsc@tpsgc-pwgsc.gc.ca.

Thank you in advance for your collaboration.

Dominic Laporte
Assistant Deputy Minister of Procurement, PSPC

Mollie Royds 
Associate Assistant Deputy Minister of Procurement, PSPC

Simon Page
Assistant Deputy Minister, Defence and Marine Procurement, PSPC

Paula Folkes-Dallaire
Associate Assistant Deputy Minister, Defence and Marine Procurement, PSPC