Question Period Note: Office of Supplier Integrity and Compliance

The Office of Supplier Integrity and Compliance supports the Government’s ability to identify suppliers of concern and take appropriate action to mitigate the risk they pose.

• The Office of Supplier Integrity and Compliance is part of a broader framework of tools that improves the Government’s ability to respond to emerging risks, and protect the integrity of the federal procurement and real property systems
  • It administers the Government of Canada’s suspension and debarment program for procurement and real property transactions
  • Since its launch, the Office has taken action against various bad actors and continues to step up efforts to identify and respond to suppliers of concern

If pressed on GC Strategies:

• In response to multiple instances of serious wrongdoing, the Office of Supplier Integrity and Compliance debarred GC Strategies from the federal procurement system for seven years under the government’s Ineligibility and Suspension Policy
• The period of ineligibility was determined by assessing the seriousness of the conduct against a prescribed set of factors
• In addition, at the end of the period of ineligibility, the supplier will be reassessed before it can be removed from the list of ineligible suppliers

If pressed on ARTS Technologies Inc.:

• Upon assessing the results of an administrative investigation, which revealed serious misconduct, the Office of Supplier Integrity and Compliance debarred ARTS Technologies Inc. from the federal procurement system for seven years under the Ineligibility and Suspension Policy
• The period of ineligibility was determined by assessing the seriousness of the conduct against a prescribed set of factors
• At the end of the period of ineligibility, the supplier will be reassessed before it can be removed from the list of ineligible suppliers

The Office of Supplier Integrity and Compliance (OSIC), launched in May 2024, replaced the Government of Canada’s Integrity Regime that had been in place since 2015 as a government-wide, policy-based debarment system. It is designed to mitigate the risk of conducting business with suppliers of concern by excluding them from being awarded contracts, as opposed to being punitive which is the role of the criminal justice system.

OSIC plays a significant role in safeguarding the federal procurement and real property systems, which encompasses approximately $20 billion annually for contracts, real property agreements, the management of Crown-owned properties, and rental payments on 1,690 lease contracts across Canada.

Under the updated Ineligibility and Suspension Policy (the Policy), changes have been introduced to enable OSIC to better mitigate risks posed by suppliers of concern. Triggers for suspension or debarment have been expanded to include:

• offences under the Criminal Code, the Financial Administration Act
• Corruption of Foreign Public Officials Act, the Canada Elections Act
• civil judgments and similar offences that occur in other jurisdictions
• misconduct related to human trafficking, forced labour, environmental violations, and labour code
• wrongdoing in the absence of charges or convictions, including in cases where a supplier has debarred by another jurisdiction or an international organization and/or cases involving a founded breach of the Code of Conduct for Procurement

Decision-making under the Policy has been delegated from the Minister of Government Transformation, Public Works and Procurement to the Registrar of Ineligibility and Suspension, an Assistant Deputy Minister-level position. The updated Policy accords the Registrar flexibility to determine appropriate periods of ineligibility, up to a maximum of 10 years, based on an assessment of aggravating and mitigating factors. This ensures OSIC’s responses are commensurate with the conduct and risk posed by the supplier.

OSIC actively monitors current events for allegations of supplier misconduct through research, information sharing, and data analytics. OSIC exercises due diligence and procedural fairness when assessing suppliers, and apply administrative safeguards to allow for independent decision making while taking action when the Policy is triggered.

The names of companies that are suspended or determined to be ineligible from being awarded a contract or real property agreement with the Government of Canada are included on a public list on OSIC’s website. Currently, two suppliers are provisionally suspended; four are suspended; seven are ineligible; and three have active administrative agreements.

Competent authorities (e.g., federal departments and agencies) are encouraged to refer cases of founded misconduct in the context of a procurement or real property agreement to OSIC for assessment. Even if departments do not report issues, OSIC can self-initiate assessments if they become aware of issues. Departments and agencies must refer cases of suspected criminality directly to law enforcement.

GC Strategies Incorporated

GC Strategies has been the subject of intense public scrutiny regarding multiple instances of misconduct in the context of federal procurements, most notably in relation to the development of the ArriveCAN application.

PSPC acted swiftly in response to allegations regarding GC Strategies Inc. In February 2024, the company was suspended from participating in PSPC procurement processes and instruments, including standing offers and supply arrangements, as well as participating in new procurement opportunities undertaken by PSPC. A decision was also made to suspend the security status of GC Strategies Inc. in March 2024.

These decisions were taken prior to the launch of OSIC and the coming into force of the revised Ineligibility and Suspension Policy. The former Integrity Regime that was in effect at the time only enabled the department to take action when a supplier was charged with or convicted of an offence listed in the prior version of the Ineligibility and Suspension Policy.

While the risks associated with doing business with GC Strategies Inc. were initially mitigated by suspending the company from participating in procurement processes and suspending its security clearance, additional information became available to OSIC that indicated that further action was required. The expanded scope of the revised Ineligibility and Suspension Policy enabled the Registrar to act.

ARTS Technologies Inc.

On June 12, 2025, ARTS Technologies Inc. was determined to be ineligible under the Ineligibility and Suspension Policy. OSIC determined this action to be warranted after assessing the results of an administrative investigation, which revealed serious wrongdoing on the part of the supplier.
Prior to the revised Ineligibility and Suspension Policy coming into force, PSPC took swift action to mitigate risks associated with this supplier. In fall 2023, ART’s security clearance was revoked by the Contract Security Program, preventing the supplier from being awarded or performing work on any contract with security requirements.
The expanded scope of the revised Ineligibility and Suspension Policy enabled the Registrar to take action to further protect the federal procurement and real property systems from the risks posed by this supplier.

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