Approval of Purchases Policy

Purpose

To establish a system of approval limits for operating expenditures to ensure that the Agency is accountable for the funds it receives.

Policy

The Annual Business Plan, as approved by the Board of Governors, shall provide the guidelines for approved operating expenditures within a fiscal year. All operating expenditures must be approved by an appropriate signing authority to ensure that the expenditure is within the approved Annual Business Plan and in accordance with the Broader Public Sector Procurement Directive.

Procedure

  1. All operating expenditures are approved by the Board of Directors through the Annual Business Planning process. (see Policy D 1.1 – Budget Development and Accountability)
  2. A schedule of Authorized Approval Limits for Operating Expenditures for Senior Leadership is submitted to the Finance Committee of the Board of Governors for approval. This schedule must be reviewed and updated on a timely basis to reflect changes in Senior Leadership and areas of responsibilities.
  3. Once approval limits have been authorized, a Program or designated Assistant Director or CAO may delegate signing authority to any member of his/her staff. However, delegation of authority limits does not delegate the responsibility of the Program or designated Assistant Director. The Program or designated Assistant Director is responsible with coordination of spending within any area where signing authority has been delegated. The Program or designated Assistant Director will be held accountable for the financial results of the programs within his/her area of responsibility.
  4. Notice of delegation of signing authorities must be forwarded to the Finance Department. The notice must include a signature specimen to place on file for reference to approved documents.
  5. The Finance department will review all source documents for the appropriate level of authorization prior to processing in the financial records of the Agency.
  6. The following Procurement Method Schedule prescribes what procurement method is to be followed based on the procurement value.
  7. All consulting services must be competitively procured through an invitational or open competitive process irrespective of value (see Policy D 3.2).
  8. Open competitive bid opportunities must be posted through an electronic tendering system, available to all Canadian suppliers. Further notice is posted on the website directing all interested parties to purchasing opportunities at the electronic tendering portal.
  9. Maximum justifiable weighting must be allocated to the price/cost component. Evaluation criteria and weighting must be clearly outlined. Contract award is based entirely on final scoring and should not be influenced by discrimination or preferential treatment. All conflict of interest must be declared on the part of the proponents or evaluators. In some cases, it could mean replacement of an evaluator to preserve transparency and fairness.
  10. Beyond the conflict of interest declaration, the evaluators must sign a non-disclosure form.
  11. Information surrounding supplier debriefing, bid dispute resolution, contract award postings should be contained in the Request for Proposal template.
  12. The overall value of the procurement cannot be divided so as to circumvent the approval thresholds.
  13. Where appropriate, a Non-Competitive form may be completed where BPS or internal policy has been contravened to justify the action. The completion of the form must ensure that it meets at least one of the exception codes contained in the form. Contravention of policy may be signed by a Program Director whereas contravention of BPS standards can only be approved by the CEO.
  14. All procurement procedures are subject to meeting specific funder contract requirements. Compliance with contract requirements overrides Lutherwood policies only when contract requirements are more stringent. It is the responsibility of the authorizing person to ensure the procurement requirements are adhered to for any funding agreement affected by authorized procurement.