Canadian Federal Government Moderates "Integrity Framework" Penalties

The Government of Canada has introduced amendments to its "Integrity Framework" to moderate the harsh impact of debarment policies that prevent companies from bidding on federal government contracts if they or their affiliates have been convicted of certain listed criminal offences in Canada or abroad. These debarment policies have been subject to intense criticism over the last fourteen months since they automatically apply even if the company self-reported the offence, cooperated with authorities, or took remedial measures.

With the recent amendments, a company may have the debarment period reduced if it cooperated with authorities or remediates the wrongful conduct. A company may also escape debarment completely if it can prove that it had no knowledge of or involvement in the offence committed by an affiliate company.