Administrative Procedure 516: Procurement (Purchasing)
Education Act: Section 171 (1)13 Powers of Boards: Provision of Supplies; Section 286 (i) Duties of Supervisory Officers: Supervise Business; Part IX Division A – General Finance; Broader Public Sector Accountability Act 2010: Broader Public Sector (BPS) Expenses Directive; Broader Public Sector (BPS) Procurement Directive; Canadian European Union Comprehensive Economic and Trade Agreement; Canadian Free Trade Agreement; Trade and Cooperation Agreement Between Ontario and Quebec; Accessibility for Ontarians with Disabilities Act (AODA)
Administrative Procedure (AP) 440 Employee Conflicts of Interest; AP 509 Petty Cash; AP 513 School Generated Funds – Accounting Procedures; AP 515 Travel and Expense Reimbursement; AP 518 Hospitality; AP 520 Surplus Assets; AP 540 Hazardous Materials Disposal; AP 570 Maintenance, Repair and Care of Property
1. Purpose of this Administrative Procedure
This administrative procedure is intended to provide procurement and purchasing guidelines, rules and instructions for the efficient and cost-effective acquisition of goods and services at Avon Maitland District School Board (the “Board”). The consideration of efficient and cost-effective acquisition, for the purposes of this administrative procedure, will be the "Total Acquisition Cost" method of procurement (i.e. consideration of all costs, including acquisition, currency exchange, sales taxes, installation, removal, operating and disposal costs etc.) rather than only the lowest unit price.
This administrative procedure recognizes that fair and open competition is a basic principle of public procurement and is accomplished using a variety of procurement and source selection methods. Open competitive bidding promotes the most cost-effective use of Board funds and allows the Board to obtain optimum quality, price, delivery and performance of required goods and/or services.
2. Scope of the Administrative Procedure
This procedure applies to any individual who acquires products or services on behalf of the Board. These include all purchases funded by any source considered Board revenue, including but not limited to: purchases by/for departments, schools, school councils, grants from outside sources, the Centres for Employment and Learning, special projects, initiatives or committees and any other related organizations.
3. Procurement Practices in Compliance with the Code of Ethics
All procurement decisions of the Board will be guided by the Ontario Broader Public Sector (BPS) Supply Chain Code of Ethics, and the National Institute of Governmental Procurement Services (NIGP) Code of Ethics. The Board expects honesty and integrity, professionalism, responsible management and the serving of public interest to be primary values in its procurement decisions.
The above codes of ethics do not supersede the Board’s Code of Ethics, but supplements the Board’s code with supply chain specific standards of practice. The intent is to establish that the conduct of all individuals involved with Board supply chain activities must be in accordance with the Code. The Code of Ethics of the Board includes both statements below:
3.1 Avon Maitland District School Board Supply Chain Code of Ethics:
This Code of Ethics applies to any individual, company or organization that is or will procure products and services on behalf of the Board, regardless of the funding source. This defines the acceptable behaviour of those involved in the planning, purchasing, contracting, logistics and payments involved in supply chain activities.
3.2 Ontario Broader Public Sector Supply Chain Code of Ethics:
The goal of this Code of Ethics is to ensure an ethical, professional and accountable BPS supply chain.
3.2.1 Personal Integrity and Professionalism.
Individuals involved with Supply Chain Activities must act, and be seen to act, with integrity and professionalism. Honesty, care and due diligence must be integral to all Supply Chain Activities within and between BPS organizations, suppliers and other stakeholders. Respect must be demonstrated for each other and for the environment. Confidential information must be safeguarded. Participants must not engage in any activity that may create, or appear to create, a conflict of interest, such as accepting gifts or favours, providing preferential treatment, or publicly endorsing suppliers or products.
3.2.2 Accountability and Transparency.
Supply Chain Activities must be open and accountable. In particular, contracting and Procurement Services activities must be fair, transparent and conducted with a view to obtaining the best value for public money. All participants must ensure that public sector resources are used in a responsible, efficient and effective manner.
3.2.3 Compliance and Continuous Improvement.
Individuals involved with Procurement Services or other Supply Chain Activities must comply with this Code of Ethics and the laws of Canada and Ontario. Individuals should continuously work to improve supply chain policies and procedures, to improve their supply chain knowledge and skill levels, and to share leading practices.
3.3 In addition, Board employees shall operate and conduct their procurement decisions and actions based on the following:
- Work with the highest ideals of honour and integrity in all business relationships in order to merit the respect and inspire the confidence of the Board and the public being served;
- Subscribe to and work for honesty in buying, and denounce all forms of improper business practice;
- Optimize the use of resources to provide the maximum benefit to the Board and its students and consider first the interest of the Board and its students in all transactions;
- Do not use the authority of public office for personal benefit. Employees should accept no business gifts other than items of small intrinsic value. Reasonable hospitality is an accepted courtesy of a business relationship. The frequency and nature of gifts or hospitality accepted should not be allowed when the recipient might be perceived to have been influenced in making a business decision as the consequence;
- Seek or dispense no personal favours during business transactions, and handle each procurement objectively and empathetically without discrimination; and,
- Seek counsel from the Board’s Procurement Services Department, prior to initiating procurement activities, as required.
3.4 The Ontario BPS Supply Chain Code of Ethics must be posted in each school’s administrative offices, Board site and department.
The Code of Ethics Poster is available on The Core (Financial Services → Procurement Info & Resources).
4. Conflict of Interest regarding Procurement Activities:
4.1 A conflict of interest exists where the decisions made and/or the actions taken in the exercise of duties by a Board employee, Trustee, member of a statutory committee or council of the Board, including School Council members, could be, or could be perceived to be affected by the personal, financial or business interest of that person or that person’s family or business associates.
4.2 Employees are responsible and accountable for using good judgment in the exercise of the Board’s duties and must:
4.2.1 Have a familiarity with Administrative Procedure 440 - Employee Conflicts of Interest and the rules therein;
4.2.2 Disclose in writing any conflict of interest in a procurement decision to their supervisor; and,
4.2.3 Avoid situations, which may present a conflict of interest while dealing with persons or organizations doing business or seeking to do business with the Board.
4.3 In a conflict of interest situation, Trustees and members of statutory committees or councils of the Board are governed by the Municipal Conflict of Interest Act.
4.4 School Council members are governed by their individual School Council’s Conflict of interest By-laws (as required by Ontario Regulation 612/00).
4.5 In addition, the Education Act of Ontario in Chapter E.2, Section 217 states:
“Promotion or sale of books, etc., by employees of board or Ministry to board, pupil, etc., prohibited. 217 (1) No teacher, supervisory officer or other employee of a Board or of the Ministry shall, for compensation of any kind other than their salary as such employee, promote, offer for sale or sell, directly or indirectly, any book or other teaching or learning materials, equipment, furniture, stationery or other article to any board, provincial school or teacher’s college, or to any pupil enrolled therein. R.S.O. 1990, c. E.2, s. 217 (1).” and,
“Employment of employee of board or Ministry to promote sale of books, etc., to board, pupil, etc., prohibited. (3) No person or organization or agent thereof shall employ a teacher, supervisory officer or other employee of a board or of the Ministry to promote, offer for sale or sell, directly or indirectly, any book or other teaching or learning materials, equipment, furniture, stationery or other article to any board, provincial school or teachers’ college, or to any pupil enrolled therein, or shall, directly or indirectly, give or pay compensation to any such teacher, supervisory officer or employee for such purpose. R.S.O. 1990, c. E.2, s. 217 (3).”
5. Role of the Procurement Services Department
5.1 The objective of the procurement function is to provide departments, schools and sites with the professional expertise required to procure goods and services in the right quality and quantity, in a timely, efficient and effective manner.
5.2 It is the objective of the Procurement Services Department to promote procurement processes and decisions which meet the needs of learners, educators, and staff and are consistent with the ethical and strategic objectives of the Board, including:
- Compliance with the Ontario Education Act and Ministry of Education Guidelines;
- Compliance with the Broader Public Sector Procurement Directive;
- Compliance to the Ontario Broader Public Sector Supply Chain Code of Ethics;
- Compliance with any applicable international or inter-provincial trade agreements;
- Compliance with established, generally accepted procurement practices;
- Participation in cooperative purchasing, where beneficial and/or required;
- Support local and Canadian business and industry when possible; and
- Preservation of the natural environment by promoting waste reduction and recycling.
5.3 In order to meet these objectives, the Procurement Services Department will:
- Facilitate the acquisition and disposal of goods and/or services required by the Board;
- Promote the most cost effective and efficient use of Board funds by the attainment of optimum quality, quantity, price, delivery and performance;
- Promote the total acquisition cost method of procurement, as defined in Section 1;
- Ensure appropriate approval levels, as defined in Appendix A of this administrative procedure, are complied with;
- Use established professional purchasing practices to provide guidance to Board employees in their procurement activities;
- Follow their internally established guidelines for the procurement of appliances and furnishings;
- Ensure the procurement related segregation of duties rules are followed, or where not possible, implement compensating controls to address areas of risk;
- Provide training and support to employees and departments in the application of this administrative procedure, and in general procurement processes;
- Review procurement practices of all staff to ensure this administrative procedure is followed and raise discrepancies to Board Senior Administration. Specifically, the Manager of Procurement Services shall oversee and authorize the issuance of quotations for pricing, bid documents, and contractual commitments in accordance with this Administrative Procedure; and,
- Complete a compliance review of Purchase Requisitions as follows:
- Procurement Services Lead - up to $9,999.99
- Manager of Procurement Services - up to $99,999.99
- Financial Services Administrator - $100,000.00 and over
6. Segregation of Duties Rule
6.1 Segregation of duties prevents any one person from controlling the entire procurement process by segregating approvals for the key stages of the supply chain process. Where possible, the Board will segregate the procurement roles in order to comply with the segregation of duties rule. In cases where this is not possible, such as when a limited number of staff members are available to support the process, the Financial Services and Procurement Services Departments will put in place compensating controls to address areas of risk.
6.2 The five procurement roles that require segregation are listed below:
|Purchase Requisition (if applicable -see Appendix A)||Entry of goods/services order via a Purchase Requisition in the Board’s electronic requisition system||School/Departmental support staff|
|Budget Responsibility||Authorize funding is available to cover cost through approval of Purchase Requisition in the Board’s electronic requisition system||School/Departmental Leader responsible for a budget|
|Purchase Commitment||Authorize release of the purchase order to the vendor under agreed-upon contract terms||Procurement Services Staff (Purchase Requisition submitted) or School/Departmental Staff|
|Receipt of Goods/Services||Authorize that the order was physically received, correct and complete||Board staff receiving the goods or services|
Authorize payment to the vendor
Release of Payment to the vendor
School/Departmental Leader responsible for a budget
Accounts Payable Staff or School Secretary
7. Index of Appendices and Purpose
In addition to this Administration Procedure, a series of appendices are available to detail topic specific items and outline detailed processes. The list of appendices along with their topic and purposes are listed in the below table.
|Appendix Number||Appendix Title||Purpose|
|Appendix A||Procurement Approval (Signing) Authority||Details the allowable, dollar value approval levels of Board staff|
|Appendix B||Procurement Methods||Describes the various forms of procurement that Board staff should use to purchase goods or services|
|Appendix C||Competitive Procurement Methods||Describes the various formal competitive procurement methods|
|Appendix D||Vendors||Details the set-up process for new vendors and monitoring of existing vendors|
|Appendix E||Accessibility for Ontarians with Disabilities Act (AODA) Compliance||Describes the process to ensure vendors are compliant to AODA|
|Appendix F||Procurement Compliance Reviews||Details the review of Board procurement activities to be completed by the Financial Services Department|
|Appendix G||Procurement Definitions||A list of commonly used procurement terms|
Appendix A - Procurement Approval (Signing) Authority
Appendix B - Procurement Methods
Appendix C - Competitive Procurement Methods
Appendix D - Vendors
Appendix E - AODA Compliance
Appendix F - Procurement Compliance Reviews
Appendix G - Procurement Definitions
Revised April 2022