CANARIE Supplier Code of Conduct
Purpose and Scope
This Supplier Code of Conduct (“Code”) sets out the principles and expectations as to how organizations, including their representatives and employees, and subcontractors (together “Suppliers”), who supply goods and services to CANARIE, are to conduct business with and deal with CANARIE.
Our values are built on anticipating and delivering reliable service to our stakeholders; collaborating and taking ownership for personal and collective high performance; contributing to a culture that develops expertise and fosters creativity; embracing diversity for innovation and growth; and holding ourselves to the highest standards of integrity. Our organization, and all our employees, are accountable and have a duty to comply with applicable laws and regulations and are expected to behave responsibly and ethically.
CANARIE has a responsibility to maintain the confidence of the supplier community and the Canadian public when acquiring goods and services in support of government-funded programs by conducting procurement activities in a fair manner.
We expect Suppliers and their subcontractors to be aware of and comply with this Code and to operate in accordance with values comparable to ours, and in a manner which is consistent with prudent business practices. It is also our expectation that Suppliers acknowledge the Code.
Where there is a conflict between the language in the Code and the agreement for products and services (Master Services Agreement or Master Supplier Agreement) between CANARIE and the Supplier, it is understood that the terms in the executed agreement will apply.
Failure to comply with this Code will result in the Supplier being placed on enhanced monitoring and may result in the termination of the Supplier’s relationship with CANARIE, in accordance with the applicable agreement.
In all their activities, Suppliers must ensure they conduct themselves in compliance with the applicable laws, rules, and regulations of the jurisdictions in which they operate.
Conflicts of Interest
In their relationship with our employees, Suppliers must not try to gain improper advantage or preferential treatment for other relationships they may have with us or improperly impact a CANARIE employee’s ability to make sound, impartial, and objective decisions on behalf of CANARIE.
Suppliers are required to disclose any situation that appears to conflict, or could conflict in any way, with the interests of CANARIE and should have clear company-wide policies or processes on managing conflicts of interest.
Gifts and Entertainment
The nature of any gifts or entertainment must not, by their quality, quantity, or timing, be used by Suppliers to gain improper advantage or preferential treatment from CANARIE employees. The CANARIE Conflict of Interest Policy has prescribed limits in place that our employees must adhere to, including a $100 gift limit. Suppliers are to inform their employees of the requirements and comply with these limits, as well as maintain appropriate records of exchanges of gifts and / or entertainment with our employees. For greater clarity, the exchange of cash, cash equivalents, bonds, or negotiable securities is prohibited. No gifts or entertainment are permitted during a CANARIE Request for Proposals process, where the Supplier is responding.
Anti-bribery and Anti-corruption
Suppliers must not engage directly or indirectly in any activities that would put CANARIE at risk of violating anti-bribery and anticorruption laws.
Suppliers must comply fully with all their obligations in relation to all taxes due within the jurisdictions in which they operate. Suppliers must not participate in tax evasion or facilitate tax evasion by others. Specifically, we expect our Suppliers to have contracts, policies, systems, and / or procedures in place to ensure that all who act for them or on their behalf, also comply with such obligations.
The notice will be placed on our website and at our administrative office.
Non-Public Information and Information Barriers
In their dealings with CANARIE, if Suppliers become aware of non-public information about CANARIE or our clients, we expect Suppliers to have in place policies and procedures for the proper safeguarding, handling, and use of that information (such as information barriers). These policies and procedures must meet applicable legal and regulatory requirements to prevent inappropriate access, use or disclosure of non-public information.
Responsible Business Practice
Privacy and Information Security
Suppliers must process and store information as agreed with CANARIE and have appropriate privacy / data protection and information security policies and procedures in place to protect personal and confidential information. Suppliers must notify CANARIE immediately (and for certainty, within a week) of any actual or suspected privacy breaches, security breaches, or losses of our information. Further, Suppliers must assist CANARIE in managing any consequences arising from such events.
Business Resumption and Contingency Planning
For some services performed by Suppliers, due to the significance for our business or the types of activities that may be involved, we expect that the Supplier’s business continuity and disaster recovery plans are developed, maintained, and tested in accordance with applicable regulatory, contractual, and service level requirements.
Outsourcing and Subcontracting
Suppliers are not to subcontract services they perform for CANARIE or outsource activities that directly impact the delivery of goods and services to CANARIE, without our prior knowledge and written approval. In situations where approval is given, it is important for CANARIE to know the locations of where the work will be performed, the possibility of cross-border movement of any CANARIE or CANARIE employee data, and the identity of parties involved in the provision of the services.
In addition, where Suppliers are outsourcing certain activities in connection with CANARIE, Suppliers must monitor the outsourcing or subcontracting engagement to ensure compliance with the Suppliers’ contractual obligations and with this Code and provide evidence of such monitoring to CANARIE upon request.
Suppliers must have appropriate management policies and procedures in place to minimize material environmental impacts and comply with all environmental laws. Suppliers are also encouraged to integrate environmental sustainability into company policies and business practices. Suppliers are encouraged to develop targets to reduce the environmental impacts of their operations, products, and services and to publicly disclose their progress relative to those commitments on an ongoing basis.
Responsible Treatment of Individuals
Respect and Diversity
Suppliers must maintain workplaces characterized by professionalism, and respect for the dignity of every individual with whom their employees interact, including respect for differences such as gender, gender identity, gender expression, race, colour, age, disability, sexual orientation, ethnic origin, and religion. Suppliers must not tolerate harassment, discrimination, violence, retaliation, and other disrespectful or inappropriate behaviour.
Suppliers must respect the dignity of their own employees and others, adhere to principles of diversity and maintain a respectful workplace. Please see CANARIE’s website for more information about CANARIE’s expectations regarding Equity, Diversity, and Inclusion.
At CANARIE, we strive to have an inclusive supply chain. CANARIE expects its Suppliers to embrace inclusive procurement practices to advance equality of opportunity for women, BIPOC, LGBT+, people with disabilities, service-disabled, and veteran-owned businesses by promoting an inclusive supply chain and levelling the playing field for diverse suppliers.
Employment Practices and Human Rights
Suppliers must abide by applicable employment standards, labour, non-discrimination, and human rights legislation. Where laws do not prohibit discrimination, or where they allow for differential treatment, we expect Suppliers to be committed to non-discrimination principles and not to operate in a way that unfairly differentiates between individuals.
CANARIE is committed to taking the actions set out in our Human Resources Policies to meet the responsibility of businesses like ours to respect human rights. We expect our Suppliers to share our commitment to human rights, and we will take appropriate action to mitigate risks to human rights to which we may be directly linked.
Suppliers must be able to demonstrate that, in their workplaces:
- Child, forced, or compulsory labour is not used.
- Discrimination and harassment are prohibited.
- Retaliation for speaking up is prohibited and employees are free to raise concerns and speak up without fear of reprisal.
- Appropriate and reasonable background screenings have been conducted to ensure the integrity and good character of the Supplier’s employees.
- Clear and uniformly applied employment standards are used that meet or exceed legal and regulatory requirements.
Suppliers will respect the rights and freedoms of Indigenous Peoples. If engaging in activities that may infringe upon Indigenous or treaty rights, Suppliers are expected to share this information with CANARIE. This will help to ensure open and authentic engagement with Indigenous Peoples and to safeguard constitutionally protected rights.
Health and Safety
We expect Suppliers to provide healthy and safe workplaces and comply with relevant health and safety laws. Suppliers are also expected to provide all their employees with adequate information and instruction on health and safety concerns and to enable their employees to meet their responsibilities for the maintenance of a healthy and safe workplace.
Information and Data Management
Data Retention and Destruction
Suppliers must retain and securely destroy data in accordance with criteria established in the executed supplier agreement and in line with local regulatory requirements and provide confirmation and/or evidence of destruction upon request.
Suppliers must not destroy CANARIE data that may be relevant to actual or anticipated legal or regulatory proceeding of which the Supplier becomes aware or for which they receive notification. Suppliers must take reasonable measures and maintain adequate internal data maintenance policies to ensure proper compliance with their obligations to CANARIE.
In their dealings with CANARIE, Suppliers must protect CANARIE information throughout all stages of the information life cycle, including creation/collection, storage, use, transmission, transporting, archiving, and destruction and use suitable methods of encryption where required.
Suppliers must have policies and procedures in place to approve, grant, remove, deactivate, and periodically review access to CANARIE information and services to ensure that the level of access is appropriate and remove unnecessary access without undue delay.
Monitoring and Reporting of Violation
Monitoring and Reporting of Violation
CANARIE maintains the right to monitor a Supplier’s compliance to the Code and audit a Supplier’s control environment. CANARIE will be entitled to request information from its Supplier as to their compliance with the principles of this Code of Conduct.
Any person with reason to believe that the spirit or principles of this Code are not being respected by a CANARIE Supplier is asked to report to:
CANARIE Supplier Risk
The reporting of a violation of the Code may lead to an evaluation and an investigation by CANARIE if warranted. Failure to comply with this Code will result in the Supplier being placed on enhanced monitoring and may result in termination of the Supplier’s relationship with CANARIE, in accordance with the applicable agreement.
Suppliers Operating in Canada
In addition to acknowledging the Code, CANARIE’s expectation is that Suppliers that operate their business and provide services within Canada will support our commitment to Canadian jobs and prosperity and meet the following requirements.
- Suppliers will notify CANARIE immediately if they have been found in breach of any Canadian Human Rights, employment standards (legal and regulatory), or immigration laws.
- Suppliers will not implement any material change to the way services are provided to CANARIE that has an impact on the Suppliers’ employees, without consulting CANARIE to ensure there is no breach of our policies and the Code.
- In addition to obtaining CANARIE’s specific written consent before sub-contracting services, Suppliers will be required to provide to CANARIE, and keep up to date as necessary, any information about subcontractors CANARIE may reasonably require.
- Suppliers, by their action and in collaboration with CANARIE, will continue to create investment and jobs in Canada in the provision of services to CANARIE.