Code of Conduct for Procurement

Outlines expectations and obligations for vendors and their sub-contractors who respond to bid solicitations and/or provide goods and services to Canada.

This code may be amended periodically.

This code was updated to simplify its language and to reflect the amendments to the Directive on the Management of Procurement that make this code mandatory for all Government of Canada procurements.

Effective date

This code is effective as of May 26, 2023.

The code that was in effect at the time of the signing of the contract continues to apply.

Prior to the effective date, the following still apply:

1. Purpose

The Government of Canada has a responsibility to maintain the confidence of the vendor community and the Canadian public when acquiring goods and services in support of government programs by conducting procurement activities in an open, fair and transparent manner. In Canada, fairness, openness, and transparency are assured through compliance with various acts, regulations, policies, international instruments adopted by Canada, Canada's international and domestic trade agreements, and labour cooperation agreements.

The Government of Canada is committed to upholding international human and labour rights, including fundamental principles and rights at work covered by International Labour Organization (ILO) 8 fundamental conventions and the United Nations Universal Declaration of Human Rights, the United Nations Guiding Principles on Business and Human Rights, and the Organization for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises.

The Government of Canada requires its vendors and their sub-contractors to operate lawfully and expects them to conduct their activities in a socially and environmentally responsible manner by, at a minimum, meeting the expectations and obligations set forth in this Code of Conduct for Procurement (“the code”).

The code is a statement of expectations and obligations for vendors and their sub-contractors.

2. Definitions

See Appendix A: Glossary of terms

3. Application

The code applies to all vendors and their sub-contractors who respond to bid solicitations and/or provide goods and services to Canada. In fulfilling the terms of their contracts, vendors and their sub-contractors are required to comply with all applicable laws and regulations.

Vendors are required to alert their contracting authority as soon as they are made aware that they may not be in compliance with the code. Canada will work with vendors 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 vendors or their sub-contractors are unable or unwilling to comply with the code, Canada 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, suspending or cancelling the supply arrangement.

The Government of Canada expects vendors to share the expectations set forth in this code with their sub-contractors.

4. Ethics and professionalism

Vendors must respond to bid solicitations, requests for standing offers, and requests for supply arrangement in an honest, fair, and comprehensive manner that accurately reflects their capacity to satisfy the requirements stipulated in the bid/offer/arrangement or contract documents. Vendors may submit bids/offers/arrangements and enter into contracts only if they are able to fulfill all stipulated obligations. Furthermore, vendors and their sub-contractors have a duty of good faith and honest performance, before and during the procurement process.

5. Conflict of interest

By submitting a bid/offer/arrangement, vendors warrant that no real, apparent or perceived conflict of interest exists or is likely to arise in the performance of the contract. If vendors become aware of any matter that causes or may cause a conflict of interest, they must immediately disclose the matter to the contracting authority in writing.

6. Environmental protection

Vendors and their sub-contractors have a key role to play in advancing the government's environmental objectives by providing goods and services that have a lesser or reduced impact on the environment. Key environmental considerations include reduction of greenhouse gas emissions, improved energy efficiency, use of renewable resources, waste reduction, reduction of plastics and packaging, and reduction of hazardous waste.

In addition to being aware of Canada’s international environmental and climate commitments such as the United Nations Framework Convention on Climate Change and the Paris Agreement, vendors and their sub-contractors are expected to familiarize themselves with the Policy on Green Procurement, which sets forth Government of Canada expectations requiring the integration of environmental considerations into the procurement process. Vendors and their sub-contractors are additionally expected to ensure that the packaging and durability of their goods is sustainable.

7. Abuse and harassment

Vendors and their sub-contractors will ensure that all their interactions with their workers uphold the principles of dignity and respect. Physical, sexual, verbal harassment and/or violence, bullying, teasing or other aggressive behaviour are strictly prohibitedFootnote 1 . Vendors and their sub-contractors are expected to foster and encourage a positive, harmonious, and professional work environment in their interactions with their workers. These principles apply equally to interactions with public servants.

8. Human rights and labour standards

Canada expects vendors to guarantee workers’ labour and human rights in their main operations and their supply chains, including:

8.1 Terms of employment

Vendors and their sub-contractors are expected to provide workers with a written employment contract outlining the terms of employment, in a language understood by the employee.

8.2 Wages and benefits

Vendors and their sub-contractors must pay at least the legal minimum and overtime wages for hours worked, and wages must be paid directly to the worker or to a worker-controlled account. In addition, workers must not be charged any recruitment fees or related costs.

8.3 Regular working hours and overtime hours

If overtime is necessary, vendors and their sub-contractors must inform workers of such employment precondition prior to the time of hire, in advance of the overtime shift, and they must ensure workers are given the option to refuse to work overtime without punishment, penalty or disciplinary action.

8.4 Discrimination

Vendors and their sub-contractors must not engage in discriminatory hiring and employment practices based on race, nationality or ethnicity, colour, religion, age, sex (including maternity, pregnancy and the possibility of pregnancy), sexual orientation, gender (including gender identity or expression), marital status, genetic characteristics, disability, language, or conviction of any offence for which a pardon has been granted or in respect of which a record of suspension has been orderedFootnote 2 .

8.5 Freedom of association and collective bargaining

If applicable, vendors and their sub-contractors are expected to grant their workers their right to join or form trade unions of their own choosing and to bargain collectively with their employer.Footnote 3 

8.6 Grievance mechanism

Vendors and their sub-contractors are expected to provide an anonymous and confidential method for all workers to raise concerns to senior management without fear of retaliation.

9. Indigenous rights

Vendors and their sub-contractors will respect the rights and freedoms of Indigenous Peoples. If engaging in activities that may infringe upon Indigenous or treaty rights, vendors and their sub-contractors are expected to share this information with Canada, as early in the planning stages as possible. This will help to ensure open and authentic engagement with Indigenous Peoples and to safeguard constitutionally protected rights.

10. Human trafficking, forced labour and child labour

The Government of Canada is committed to upholding the Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children, supplementing the United Nations Convention against Transnational Organized Crime. Canada expects its vendors and their sub-contractors to respect their workers’ workplace rights, and take steps to mitigate human trafficking risks and monitor compliance of labour and human rights in their supply chain. 

10.1 Human trafficking

All vendors’ workers will work voluntarily and not be subjected to any form of exploitation, such as human trafficking for the purpose of forced labour or sexual exploitation. Vendors and their sub-contractors will not engage in any form of human trafficking activities.

10.2 Forced labour

Vendors and their sub-contractors will comply with Canada’s prohibition on the importation of goods produced, in whole or in part, by forced or compulsory labour. This includes forced or compulsory child labour and applies to all goods, regardless of their country of originFootnote 4 .

10.3 Child labour

All workers must be of at least the legal minimum age based on the applicable laws and regulations. Workers under the age of 18 must not perform hazardous work that may jeopardize their health or safety. Hazardous work includes work which exposes children to physical, psychological or sexual abuse; work underground, under water, at dangerous heights or in confined spaces; work with dangerous machinery, equipment and tools, or which involves the manual handling or transport of heavy loads; work which may expose children to an unhealthy environment; work under difficult conditions, including long hours of work or work where the child is unreasonably confined to the premises of the employerFootnote 5 .

Appendix A: Glossary of terms

Applicable laws and regulations

mean all national, local and other applicable laws and regulations that apply to the performance of the Contract, including laws and regulations of the country where the good is produced or service provided.

Child labour

means any work that deprives young persons of their childhood, their potential and their dignity, and that is harmful to physical and mental development, and interferes with their schooling.


means this Code of Conduct for Procurement.


means a legally binding agreement between Canada and a vendor to provide goods or services to the Government of Canada.

Contracting authority

means the person authorized to enter into a contract on behalf of Canada.

Forced labour

is all work extracted from a person under the threat of a penalty and for which the person has not offered himself or herself voluntarily.


means any articles, commodities, equipment, goods, materials or supplies and includes printing or the reproduction of printed matter and the construction or repair of a vessel.

Human trafficking

involves the recruitment, transportation, harbouring and/or exercising control, direction or influence over the movements of a person in order to exploit that person, typically through sexual exploitation or forced labour.

Public servant(s)

means any person employed in the federal public sector, this includes the core public administration, Crown corporations and separate agencies.

Recruitment fees

or related costs refer to any fees or costs incurred in the recruitment process in order for workers to secure employment or placement, regardless of the manner, timing or location of their imposition or collection.


means the provision of services to another with no day-to-day supervision or control by Canada. It normally implies the accomplishment of a specified job or task to achieve a prescribed objective.

Standing offer

means an offer from a vendor to Canada to deliver goods and/or services in accordance with pre-set prices, terms and conditions during a specific period. A standing offer is not a contract. The issuance of a call-up by Canada against a standing offer constitutes acceptance of the offer and results in the creation of a contract.


means any entity that takes a portion of a contract from the principal or prime contractor or another sub-contractor.

Supply arrangement

means a non-binding arrangement between Canada and a pre-qualified vendor that allows Canada to solicit bids and award contracts from a pool of pre-qualified vendors for specific requirements within the scope of the supply arrangement.

Supply chain

is the network of organizations involved in the transformation and creation of a product from sourcing the raw materials, and manufacturing, to the main business selling the finished goods to consumers.


means any person or other legal entity who has submitted a bid/offer/arrangement or who has been awarded a contract, a standing offer or a supply arrangement.


means any current or former labourer, employee, or staff member employed or contracted with by the vendor, including all foreign and migrant workers.

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