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Compliance | 37 minutes
Compliance and internal risk management in procurement is tricky business. A lot can go wrong, landing your team—and sometimes your whole organization—in hot water.
We had the opportunity to host a panel discussion with four seasoned procurement pros during our OntarioTalk event, and they had a lot of great advice on the subject. While this discussion was intended for public procurement departments in Ontario, most of this advice applies to any and all public agencies.
In this episode, Bonfire’s Barb Lima moderates a conversation between:
Tune in as panelists give their take on creating clear and accessible policies and procedures, the importance of leadership support, how to approach internal client education, creating a system of checks and balances, and introducing sustainable procurement initiatives in the mix.
You can find this interview, and many more, by subscribing to Inside Public Procurement on Apple Podcasts, on Spotify, or gobonfire.com/podcast.
Listening on a desktop and can’t see the links? Just search for Inside Public Procurement in your favorite podcast player.
Hend Salem, Carol Izzio, Christine McParland, Luca Del Grosso |
Speaker 1: You’re listening to Inside Public Procurement by Bonfire, a show celebrating the unique stories and heroic efforts of those on the front lines of public procurement. Each episode we bring you the latest trends, tips and real stories from procurement trailblazers like you who worked tirelessly to bring positive impact to the agencies and communities you serve. Together, let’s elevate the field of public procurement to new heights.
Now, [00:00:30] pull up a chair, and let’s gather around the bonfire. Our show is about to begin.
Tuong La: Hello and welcome to the Inside Public Procurement Podcast. My name is Tuong La, and I’m the podcast producer at Bonfire, an e-procurement solution used by over 600 public agencies in North America.
For today’s episode, listen in on a conversation had during our Ontario Talk Panel Discussion. While this event was intended for Ontario procurement pros, the topics in this talk apply [00:01:00] to every jurisdiction. Bonfire’s Barb Lima moderates as four seasoned procurement pros give their takes on ways they and their internal clients approach regulatory compliance and manage risks while juggling other priorities like sustainability, new corporate policies, and much more.
So sit back by the bonfire, relax, and enjoy the episode.
Barb Lima: Welcome Ontario and anyone else that’s viewing outside of Ontario to today’s webinar. Depending on where you’re joining us from Ontario today, the sun seems to be making an appearance across [00:01:30] the province, so hopefully Wiarton Willie is going to hold his promise to an early spring, so that will make the rest of us Ontarians happy.
We have a few hot topics that we’ll be discussing with our panel today, so let’s get into it.
So part of today’s discussion will be all about Ontario procurement. And my name is Barb Lima, I’m an e-procurement specialist here at Bonfire, and I will be your moderator for today. We will be discussing all things related to Ontario procurement for the remaining hour and I’m thrilled to introduce you to our panel of experts who [00:02:00] will be sharing their personal experiences and perspectives on today’s topics.
So from left to right, Christine McParland. She joined St. Lawrence College in 2013 and has since worked in a variety of capacities within procurement and ancillary services. During her time as the Associate Director of Procurement, Christine has managed several third-party service contracts while managing the ancillary services portfolio for the past six years. She has over 20 years of procurement experience within the public sector, starting out in healthcare before [00:02:30] moving to the education sector, and she holds a Public Buyer Certificate from the Ontario Public Buyers Association. She also received her designation from Supply Chain Canada in 2019. Welcome, Christine.
Luca Delgrosso is currently a Procurement Manager at the Technical Standards and Safety Authority with approximately 12 years of experience in various industries within the public sector. He started his career in healthcare at Mount Sinai Hospital in Toronto as a procurement assistant and later at Sunnybrook Health Sciences Center as their strategic [00:03:00] sourcing and contract specialist. In healthcare, Luca’s focus was goods and services related to IT, research, medical devices and equipment, consulting services and some redevelopment projects. Recently, he became the procurement department manager overseeing all of the organization’s purchasing activities. Excited to have you today, Luca.
With over 17 years of experience in public procurement, Carol Izzio is the Director of Procurement at Sheridan College in Oakville, Ontario. Carol previously worked in healthcare, managing contracts and procurement processes with the hospitals across Canada. [00:03:30] Now in education, Carol is concentrating on using all paths and resources to ensure that procurement has a more consistent and valued approached for Sheridan. So thanks for joining us today, Carol.
Hend Salem, Strategic Sourcing Manager for non-clinical goods and services in the Ottawa Hospital. Hend is an accountant by background, however, she found her aspiration working in supply chain. She comes with over 20 years of experience, 11 which were dedicated to leading positions and procurement. Hend completed her study of bachelor degree [00:04:00] in accounting in addition to her master’s studies in finance and investment back in 2000, and she’s currently pursuing a certification in Canadian law. Thank you for joining us.
So I thought we’d jump into today’s first topic. The first question that we have for our panelists is how do you make sure that your procurement is well-documented, fair and compliant with Ontario and Canadian law? And we want to talk a little bit more about what the BPS Procurement Directive is. So I thought, Luca, maybe this would be a good question for you to kick us off with.
Luca Delgrosso: Sure, absolutely. So from my experience, one of the main things [00:04:30] about ensuring that your procurement process is well-documented, fair and compliant is basically first, just making sure your records are up-to-date and your tracking sheets and things like that, such as your bid registers. Keeping those records up-to-date is really the first step to ensuring that you have everything identified in terms of what you’ve done with your procurement processes.
Other things that have worked for me in the past is things such as checklists. You make some review checklists, things like that for documents. So when you’re going through your procurements, you can actually identify and make sure that you’ve captured things that need to be [00:05:00] in the document, your tiebreak process, things like that, you can make sure that they haven’t been removed from the documents themselves.
Some of the other things that have worked in the past as well in my personal experience is having another person from the procurement department review the documents before they get posted. So that just gives you another set of eyes to make sure. Sometimes you’re in those documents so much and making changes, that having that extra set of eyes on it just really helps to make sure that you have that kind of review and check and balance in place as well before things get posted.
Some other things that have worked in my opinion as well, or in my experience, [00:05:30] is having standard operating procedures, and that really comes into the standardization under BPS as well and just making sure that everybody in the department is processing things exactly the same, and again, one of the core pillars of the procurement directive.
And then again, something that I usually do or that has been done in the past within the procurement department is random procurement audits as well where the manager would just randomly pick files and just do checks on it to make sure that things are compliant, that things aren’t being missed, so that in the event that something is found to be missed, it’s a learning opportunity [00:06:00] for the department to make sure that we can address it and prevent those mistakes from happening in the future.
Barb Lima: Wonderful. I appreciate your perspective. Any challenges that you’ve experienced in complying with BPS?
Luca Delgrosso: So in terms of challenges, there’s always challenges. I guess in terms of challenges, it’s mainly poor planning, rush procurements, things like that, where a lot of the time we don’t have the time to do the checklist, to run through the checklist, to have someone else review it just because especially, I know we’ll get into it a little bit later, but with grants, you don’t have the time to [00:06:30] sometimes have another person in the procurement department. So that’s kind of some of the issues that I’ve experienced.
Barb Lima: Great, appreciate that. I want to open that up to the rest of the panelists. Does anyone else have any additional commentary or comments?
Christine McPar…: I’ll chime in. I agree with what Luca has said. What I really like and I’m able to lean on heavily here at the college is the BPS directives because it’s almost a checklist of 25 steps that need to be completed and then we develop those into our internal processes or our standard operating procedures. So I [00:07:00] think those directives are a really good guide to ensure we remain compliant.
Barb Lima: Wonderful. I saw Carol, you had your hand up.
Carol Izzio: Yeah, I was just going to say for us, I know it’s important to partner with third-party groups, like software, that also is very familiar with the trade agreements of the BPS so that they have, baked into some of their processes, reminders for us. So when we’re posting on a website, a popup might be, “Hey, did you know that, based on this value, you should be posting for this many days?” And so I think that that’s another [00:07:30] thing that we’ve really leveraged is working with some third-party organizations that are really in tune to what’s going on from the trade agreements and the legislation in Ontario and in Canada.
Hend Salem: I agree to everyone’s points. Honestly, what Luca mentioned makes me more comfortable that it’s not only us that we are following this, it’s actually it’s something that is across the board. We do have the compliances internally and I feel that adds a lot of value to the process. So to Luca’s point, once you work on your own document, you feel like, okay, I’m familiar with it, I know what I need to do, [00:08:00] I will change this, I’m going to remove this. But then when someone else comes and checks your document, may find other things need to be changed. So that’s definitely of added value.
Also, the internal audit. So you audit yourself before others are auditing you and you actually find this kind of good learning curve with the team and you then share it. And sometimes we even end up with changing our standard operating procedures or even updating our policy due to those continuous learnings.
Barb Lima: Great. Coming up, we do have [00:08:30] our first poll question. My organization has implemented or is in the process of implementing new technology for compliance. 70% of you say true, 20% say false, and 10% say unsure. So to our panelists or to our viewers, any surprises here?
Luca Delgrosso: From my perspective, no. I think with a lot of companies or organizations nowadays, I think most of us are on digital platforms and things like that, so I’m not really surprised.
Barb Lima: Great. Let’s jump into question number two. How are [00:09:00] you preparing to transition to a single point of access? And Christine, I want to direct this question to you, but I also want to direct it in the absence of no direction because the deadline was September 21, 2022 for the federal SPA. So I’d love to hear your comments on this.
Christine McPar…: So I think we’re all kind of sitting in the same boat waiting for some clear guidelines and direction as to where we’re to go or what we’re to do. So as far as how I’m preparing, I am operating here at the college with using the systems that we use until I’m told otherwise, [00:09:30] until something else comes down that guides me or directs me or points me in a different way.
One of the challenges I see with this single point of access is that a lot of organizations, and my colleagues on the line in this group as well, we’ve already developed processes and tools and streams for getting our information out there and it comes at a cost. So it’ll be interesting to see how it’s disseminated across the province.
Barb Lima: Absolutely. Any other comments from any of our panelists?
Luca Delgrosso: I mean, I’m happy to add a little something to that as well. [00:10:00] It’s just to build on a little bit of what Christine said too.
I think with most of us already on digital platforms such as MERX, Biddingo, OTP, those kinds of platforms, the digital transformation, like I said, is already underway and I think the transition to the single point of access is not necessarily just flipping a switch, but it is already something that’s ingrained in a lot of our day-to-day processes. It’s already using these platforms. So I think it’s just once we get instruction and more information on exactly what we’re doing and how we’re doing this, it’s just a matter of moving to [00:10:30] that platform and ensuring that we maintain our old records and data as well from our old systems.
Barb Lima: Okay. So it seems like everyone’s sitting, waiting to see what the direction’s going to be.
Hend Salem: But we know it’s coming soon. I mean, we all know Supply Ontario anyway in case, and at least if we are not thinking of one point of access for federal level or for the Canadian level, we definitely know that something for the provincial level is going to be there. So we should stay, in a way, tuned.
But to Christine’s point, we have already started our own. Each one of us [00:11:00] has started his own point of contact, and thanks to COVID, I mean maybe this is one of the rare positive points for COVID, that we started those kinds of automation early and we are now dependent on them.
Barb Lima: Yeah. Are there any concerns about moving to SPA or what those directives or directions are going to be?
Hend Salem: One important thing I can think of is definitely what are you we going to do with our current data, what we have as of now, and how are we going to transition it in a way? Do we have the right infrastructure in place or not? Is it [00:11:30] going to require different infrastructure? These are the questions that we usually have in mind, but definitely there will be more challenges once we know what kind of a single point we are supposed to work on.
Carol Izzio: Also too, is there going to be additional functionality that they’re going to be looking for that we aren’t currently tracking or is there going to be less functionality so we’re going to have to keep a separate system anyway? So I think that that’s the piece that’s a little bit of the unknown is what piece of it is going to replace what we have? And then to Christine’s point is we spent a lot of money and a lot of effort [00:12:00] into getting our systems up to where they are and is that going to be negated or is it going to just be augmented?
So we’re kind of waiting and seeing and I’m hopeful that where it is isn’t going to be… We’re not going to have to reverse engineer what we’ve already done.
Barb Lima: Okay. Well, leading into our next poll question then is how concerned would you be to learn about an impending audit of your procurement operation?
Christine McPar…: I might have a couple of sleepless nights, just saying.
Luca Delgrosso: Well, I think that’s normal. Anytime you have multiple hands into [00:12:30] operations, I think there’s always that kind of, did everyone file everything in the right spot? Has everything been signed off? Especially if things get handed off midway, employee turnover, things like that, in the back of your head, there’s always going to be something, I think in my opinion, that is in the back of your head. So you always have that at least somewhat concerned standpoint.
Carol Izzio: I would agree too. And I think for me, it’s really about what are they auditing? Are they auditing something from five years ago or are they auditing something from 12 months ago? Five years ago, I might be concerned because there are different [00:13:00] requirements. We’ve evolved, we made things neat and tidy and tighter. 12 months ago, I think I wouldn’t lose as many hours of sleep as I would if they were auditing something from a longer period of time.
So I think that that’s the timing because I think we’re getting better and we’re always improving the way that we’re documenting. We’re always improving the way we’re communicating and storing information. So five years ago, we may not have been as tight and clean.
Barb Lima: Fair, absolutely fair. So we are split here. So not concerned is 48%, so 11 of you; somewhat concerned is 43%, so 10 of you; [00:13:30] and there’s two of you, 9%, that are very concerned. So we’re pretty much split right down the middle there.
Christine McPar…: Just to add one other thing about the audit, the audit actually should not really be a concern. I agree with what Carol said. Five years ago, 10 years ago, things looked a lot different than what they do today. The audit itself actually is an opportunity to improve. It’s another set of eyes looking at what we’re doing going, “Okay, you know what? You need to tighten up here, we’ve missed this and we need to improve on it.” So it shouldn’t be looked at something as daunting but [00:14:00] as a process improvement.
Barb Lima: That is a great perspective, Christine, understanding why the audit is there. Absolutely.
Well, jumping into our third question, and Hend, I’m going to ask you to lead with this one is what kinds of internal risks do you face in procurement and how do you mitigate them and what risks do you navigate for grant spending?
Hend Salem: Okay. So I think depending on where are you within the maturity level within the procurement, you’ll face different kinds of internal risks. So there are risks that is within [00:14:30] the team itself, the procurement team itself, like making sure that everyone is well-trained, having all the templates in place, all the points that Luca has actually referred to in his first discussion. I mean, these are internal rules that we make sure that we’re following the process. So that is the first step.
I think once you cross that level and you feel like you are mature enough and you have covered your bases in a way, then you face other kinds of internal risks. Maybe it’s kind of like, are we taking the right decision in the right place? Are our end user [00:15:00] very familiar with the process and they know how they can actually mitigate the risks in their own way? Do we provide them with the right tools in place? Let’s say, if we are actually getting things out of the track, are we able to plan them properly in future?
So all those kinds of questions end up to be risks in our life, in our internal decisions in a way.
In my experience, I feel like when you put yourself in your end user’s shoes and you think from their perspective, because we have to agree, all of us want to do the best for their place, [00:15:30] but not all of us have the same understanding and the same knowledge of what are the risks of taking such a decision? So I feel like the best way is education. Education for the end user. Let them know what exactly, why procurement is there, why those guidelines are there. It’s not actually that we are policing them or policing how they’re spending their budget; it’s actually they are accountable for the budget and for the spend and for the risk as well. It’s not like a procurement policy, it’s a corporate policy. Everyone has actually to buy in and [00:16:00] understand what’s happening.
So our role in that whole process is to make sure that the policy is right, provided in the right way, directions and the educational tools in the right way. And once things doesn’t go on track in a way, like sometimes we plan everything when and we feel like we have covered everything but still, things doesn’t go on track, so we provide those tools to come up with the risk levels and make sure that everyone is aware, okay, this is the risk if we don’t do that, and which appetite of risk are we going to go with? And if we are taking that risk [00:16:30] option, how to mitigate it.
So we have provided those kinds of tools usually to the end users. We did all the time kind of a refresher for the policy each year, reach out to our end users at least once a year to do the plan. We revisit the plan each three month and we also meet with each group. We have service lines, so we meet with each group at least once a month. So these kinds of continuous meetings, it’s just to cover all the points, either educate them, know where they are within the plan, [00:17:00] see where can we actually get closer to them, and provide them with more support if we can. And if things are not going on track, just make sure that we cover them as early as possible.
Barb Lima: Yeah, that’s a fantastic perspective, Hend, is really educating those internal customers on how to best work with procurement. Any other comments from the panelists here, from your own experiences?
Luca Delgrosso: From my opinion, I think he pretty much hit the nail on the head on that. The biggest thing is I think training. That’s going to help a lot with risk mitigation and ensuring that everyone understands exactly [00:17:30] what their role is in the purchasing process.
Barb Lima: Awesome. And so Hend, you had mentioned you do internal refresher sessions. Are there any other things that other panelists are doing to ensure that their internal stakeholders are staying educated in the process?
Christine McPar…: So here at the college, we have onboarding with our HR department where new employees go through a deep dive, a two-day deep dive where they learn about each of the departments and procurement’s invited to come and give a presentation and provide them the tools that they need. And I often reach out to new hires when the announcement comes to say, “Hey, [00:18:00] I’d love to sit down with you and talk about procurement and introduce you to the team,” and the processes and help guide them along the way because I think we tend to forget people inherently are good. They want to follow rules, it’s just making sure the rules are there for them to follow. And their rule, they may be an engineer or a nurse or a faculty, they’re not necessarily a procurement specialist. This is out of their wheelhouse.
So like Hend says, it’s all about that education piece and how we deliver it and make sure that they’re coming along with us.
Barb Lima: Right. [00:18:30] Carol, go ahead.
Carol Izzio: It’s really about dialing it back to the why we’re doing this. I know it’s always interesting when we do a Procurement 101 and we start with how did BPS come about? How did the BPS directives come in? And we let them know that it isn’t something that procurement just decided in their offices that they were going to implement this. And we just kind of went back to why it happened and what the requirements are and, “Here’s the list of the 25 items. Nobody has to know that, that’s our job to know that, we make sure that you’re compliant,” and just kind of [00:19:00] make sure that they understand the why around we’re asking them to do this process.
And I think that that really resonates with them to sort of say, “Okay, so it’s really not about Sheridan’s procurement that’s making us do this. It’s really a legislation across the province that Sheridan is having to follow in order for us to be compliant.” So I think that that piece of it has really worked for us.
Barb Lima: Wonderful. And do you find that this messaging comes best from procurement or is it a leadership directive? What’s the best way to educate your internal stakeholders?
Carol Izzio: Leadership support, 100%. [00:19:30] You have to have leadership support, but I think the message coming from procurement is because we’re the ones that are going to be working with them. So really coming as to around the why, when you engage with us, this is the why. It’s really done well, but we absolutely have to have the leadership support. So if somebody says, “Yeah, okay, I understand the why, I don’t like it. I’m not doing this, I’m going to somebody else to tell me I don’t have to do this,” then at least we’re supported from that perspective.
Barb Lima: Wonderful. All right. So it sounds like education is key there, but that’s going to bring us to our third poll question, which is what is [00:20:00] the biggest obstacle your department is facing? Staffing and capacity constraints, difficulty expanding vendor diversity and competition, legacy technology systems, or other.
So I’m going to refer this to our panelists too, if you are experiencing any obstacles, would you say it’s any of them or would it be categorized under other?
Christine McPar…: Is there an, “All of the above?”
Barb Lima: All of the above! Good question.
Christine McPar…: I think they all play a part on your level of sophistication in your [00:20:30] organization where diversity may not play a part, but in some smaller organizations, it might play a huge part. So I think it all depends on where you are and your organization, if all of them apply or one or two apply.
Barb Lima: Snowball into each other, I could see that as well. All right. Well, we have the results back. Eight of you say staffing and capacity restraints, one of you says difficulty expanding vendor diversity and competition, three of you feel legacy technology systems, and the remainder are other.
So our question number four [00:21:00] here, and I really want to direct this question to Christine and Carol because I know that you’ve absolutely been pioneers and trailblazers when it comes to sustainable procurement and what you’ve been able to accomplish. So if you could touch upon sustainable procurement, how it’s become an emerging priority, how you’ve planned for it, what you’ve done historically, and then also what you’re planning for 2023 and beyond.
And I still want our other panelists to chime into this, but I think it’s really valuable to understand what Carol and Christine have done when it comes to sustainable procurement, [00:21:30] so I’m going to turn it over to you two.
Christine McPar…: Oh, thanks, Barb. Actually, I’m really excited that this question was part of today’s session. I am Chair of the OCPMA group, the Ontario Colleges Procurement Management Association. It is comprised of one member from each of the 24 colleges. And that group came together with centralized procurement. We initially started out thinking centralized procurement was going to impact the mom-and-pop shops or the small suppliers in our communities. And so our first knee-jerk reaction [00:22:00] was really looking at changing language around social procurement.
But as we came together and started to really dive into it, it actually turned out what we were trying to achieve was a whole sustainable procurement program. And so as a sector, we have collaborated, we got buy-in from our senior leadership to engage in this process, and Carol has been co-chair of the committee that has been working diligently to bring this to fruition, so I’m going to turn it back over to Carol to give you an update on where they are [00:22:30] on all the good work that they’ve been doing over the last year.
Carol Izzio: Thanks, Christine.
So what we’re doing with this subcommittee of the OCPMA group, so it’s a sustainable procurement subcommittee, is we’re really trying to establish a baseline and a toolkit for all the 24 colleges to start with. So no matter where they are in their sustainable procurement journey is really to say, “Here’s where we’re starting.” And one of the biggest things was around definition.
So you hear a lot about social procurement and you hear a lot about sustainable procurement and some people use them interchangeably, but [00:23:00] we made a conscious effort to define it as the overarching sustainable procurement with four pillars underneath, one being environmental, one being ethical, one being social, and one being indigenous. And what that allows us to do is we have four pillars today, we might have five pillars tomorrow, we might have three pillars tomorrow. As we go, sustainable procurement stays as our overarching and it allows us to move with what’s happening in the world, what’s happening in procurement, to allow us and [00:23:30] those pillars to be either consolidated, stayed the same, or expanded.
So right now, the language was really important and for us to understand, among the 24 colleges, what was going to be our baseline. So when we talked to each other, when vendors talked to them, we were all talking the same thing.
So we established that piece of it and then we went out and we hired a consultant to help us with building this toolkit. So Sheridan might be a little bit further along with how they want to implement sustainable procurement than one of the other colleges, but the toolkit is going to allow us to all [00:24:00] work from the same pool of thoughts, and pool of templates, the same idea to develop at our own pace because every college has got a little bit of a different pace in terms of where they are and the different size of their procurement departments.
We’re lucky that we have the ability to grab hold of sustainable procurement and really kind of move it forward. We’re also lucky we have a sustainability department that we’re working very collaboratively with. Some of the colleges, they don’t have that. So we wanted a one-size-fits-all temp toolkit that they could grab pieces [00:24:30] of and implement them anytime they wanted without having to reinvent the wheel from beginning to end.
And I think right now, we’ve engaged with our first couple of meetings with this consultant and we’re just trying to work around the framework to figure out where all the colleges are, what level of maturity they’re at with sustainable procurement, so that we can figure out how to help each one of them in the way that they need to be helped with the stage of their journey.
Barb Lima: Fantastic.
Christine McPar…: I was just going to say this whole process or the development of this toolkit not only is beneficial for the colleges, but it’s going to [00:25:00] be extremely beneficial for the supplier community because we’re all going to be talking the same language. Our evaluation criteria is going to be similar when we’re looking at sustainability as a high-rated criteria, so there’s going to be some synergies there for the supplier community as well.
And hopefully, underneath this social umbrella or pillar that Carol was referring to, centralized procurement will maybe not have such a huge impact on those small community providers [00:25:30] and how we can support them in still being partners with the college instead of trying to bid on a provincial or national tender to get recognized. It’s very exciting.
Carol Izzio: Yeah. And even to add to what Christine’s saying, when we talk about this social pillar to it, a lot of colleges are really focusing on the social pillar and I know Sheridan is one of them where we talk about diverse supplier community and we really look at that and how are we measuring it, how do we reach out to them, all that sort of point. And I know, Barb, one of the slides before one of [00:26:00] the questions was, is this one of your challenges? And it is, and we’re trying to figure out. It is for Sheridan and we’re trying to figure out how do we make sure that we kind of bridge that gap with people that are already working towards it, that are much further ahead than Sheridan, that we’re not starting from scratch?
So each of these pillars will have a different focus for different colleges and it might be one year is one focus, one year is the other, but at least the toolkit is going to be there. So when you’re ready to dive into one of the pillars, you’re able to grab [00:26:30] a hold of the templates that we’ve provided through this consultant initiative that we’re working on and hit the ground running as opposed to starting from scratch.
Barb Lima: Yeah, I think it’s fantastic in terms of having that foundational work for all the colleges and what that means to the greater vendor community.
So Eric has a question here. What is the best approach in developing a procurement framework that formally incorporates social responsibility sourcing into procurement practices?
Carol Izzio: So one of the big things is, and in my previous life in procurement, [00:27:00] especially in public procurement, it’s make sure you’re very conscious as to what you’re spelling out in your evaluation criteria, in what you’re asking the vendors to submit on, but also, don’t ask them to submit on something that you’re not going to evaluate them on and what you’re going to evaluate them on, make sure they note that is the case. So if you’re asking them to submit on their social responsibility or how their social practice is in the community, make sure they understand exactly how you’re going to take that.
The other piece of it is there is a lot of things that can be done. [00:27:30] We have to be very careful with the trade agreements around buying local, that sort of thing. So probably a good idea just to work within your organization to make sure that you’re not treading on any trade agreements with the language, but it’s really about simple things. If it’s a big organization, let’s say it’s construction, a big organization, where are they getting their labor? Are they using apprentices? Are they using local sub-trades? That sort of thing. You can ask questions about that and it’s really about the approach that you take and not a mandatory requirement, [00:28:00] and that if they aren’t using local trades, then they no longer are allowed to your projects. I think that that’s one of the biggest things is to make sure that it’s not a hard-and-fast rule because that’s when you get into trouble.
But formally documenting it, making sure that they know what you’re using this information for is kind of the biggest key because I know legal counsel always used to say to me, “Does the vendor community know exactly what you’re doing with the information that they’re providing to you?” Because if they don’t, then there is that little bit of question around how did you make the decision about your [00:28:30] award to this particular vendor, if you haven’t spelled out how you’re going to do it.
Barb Lima: It’s that same theme of educating, not only your stakeholders but also your vendors, especially when we’re introducing policies or procedures around sustainable procurement. But go ahead, Christine.
Christine McPar…: I was just going to say that from not knowing what institution Eric’s from or how they do it, but here, to really drive social procurement and even… Sorry, I’m going to back that up a little bit. Even our sustainable subcommittee, there was a lot of talk about how we were going to navigate this, how [00:29:00] were we going to drive this into and stay compliant with our trade agreements?
And one of the things that we had talked about was the quoting process and making sure that we can drive, that depending on your thresholds, you can drive that local spend or demand at least one quote from a supplier that might be underrepresented. So there’s lots of things that I think you can do. It’s developing the framework within your organization that aligns with your policy and aligns with [00:29:30] your procurement guidelines and what your senior leadership has an appetite for.
Carol Izzio: And I agree, and I think one of the other things that we as procurement professionals need to uphold is the legislation. So we are a responder for that, so we have to be sure that we’re comfortable, that we say at the end, “This was a fair, competitive, and open and transparent process.” And once we can say that, then we are able to move forward.
And one of the things that I said, even when Christine and I and the OCPMA group met, it’s Sheridan is still looking for best value. [00:30:00] Best value looks differently from procurement to procurement. We’re not looking at four bids and because there is maybe potentially somebody that is an underrepresented company, we’re going to award it to them because of that; we’re still looking for best value. And I know that people are saying… I think it’s a bit of a fallacy, but there is that conversation around, “Oh, well, sustainable procurement costs us more money,” and it’s not always the case.
So that’s what I think we need to keep our minds open and look at the value overall and make sure that we’re picking out value [00:30:30] that’s quantifiable, that’s defendable, and then go from that process because a lot of times, the smaller organizations have much lower overhead and they are able to provide a very sustainable product at a very, very reasonable rate that may win a bid.
What we’re looking at doing here is we’re looking at giving them the opportunity to provide that bid. So if we have a minimum of three bids required for whatever it is between 25 and 99,000, we’re asking for a fourth and [00:31:00] that be a diverse vendor. So we’re not asking to give the business to the diverse vendor, but give them the opportunity to see that bid and to give them the opportunity to be profiled in that way. And that’s really the first step towards opening up the pool of opportunities to these different diverse and social vendors, social enterprise vendors.
Barb Lima: Yeah, that’s a great point. I think it all leads back to those four pillars, which were your foundation: environmental, ethics, social, indigenous. So that’s great to hear those experiences.
Well, wanted [00:31:30] to open up to the rest of the panelists if you had any comments around sustainable procurement, if that’s top of mind or if there’s a different approach that you’re taking than perhaps Carol and Christine have with OCPMA.
Luca Delgrosso: I’m happy to weigh in on that. So at TSSA, we are starting to look at that. That is something that has come from the executive leadership team. I’m currently in the process of revising our procurement policy right now to kind of incorporate these kinds of things into it. Clearly, Carol and Christine are a little bit ahead of us, as well as other organizations.
We do fall under the OPS Directive as well, [00:32:00] so we have a couple of different directives. We do follow a little bit of BPS, we’re applicable as well based on the nature of our work. But I mean, we’re trying to navigate both directives and just make sure that we maintain that compliance as well, which has been a little bit of a struggle.
But I think having the buy-in from the executives, as Christine mentioned I think at the beginning of the section, I think that that really helps with it too because you could put requirements in there in the RFP process or in the evaluation criteria, but if you don’t have the support from the executive leadership team to actually stand behind [00:32:30] you and make sure that you provide enough waiting in those sections as well to actually make a difference, especially for environmental considerations and things like that, all you’re doing is paying it lip service, right? You’re just identifying that, “Hey, we do this,” but you don’t actually do it.
Barb Lima: Yeah, that’s a great point. I didn’t know, Hend, if you wanted to add any other comments to that?
Hend Salem: No. Actually, I’m so happy that Carol and Christine has taken a good leap into the process. We are still having some baby steps into it. So I think everyone knows this is a big discussion since maybe two years from now. I mean, everyone was trying to build up a frame [00:33:00] somehow, and I totally agree with Carol. You have to build the frame and actually explain it very well in your document. And when you are actually evaluating, you need to evaluate based on specific criteria that you have built up and what are the weightage. And this is where we are exactly now working on, like what is that they are actually weighted for each of those criteria? Are we actually, in a way, favoring someone if we’re actually getting those criteria in a higher weight somehow?
So I am really happy to hear that this is the process that Carol [00:33:30] and Christine went through because this is where we are as of now. We recently also updated our policy to support, in a way, the concept as such. So we said, “This is our policy. We are actually supporting the ASG Responsibility. This is how we see it,” and we are working on those criteria to build up within the documents and definitely to publish also on the website, so also our vendors are aware that get ready with those things. Soon we are going to be actually promoting or something.
To Carol’s point, definitely expectations from bigger companies are also different [00:34:00] than small size and middle size. So that is where you have your vendors clearly classified internally. Companies you are dealing with for longer term and longer kind of engagements would require more education, I think. And as big as they are, you need to manage them in a different way. So this is where we are actually now building that kind of a frame with the vendors as well.
Barb Lima: Wonderful. Well, it sounds like everyone is scratching the surface when it comes to sustainable procurement. Some are more ahead than the others, but it definitely warrants more conversations [00:34:30] in the future. And again, Carol and Christine, I really appreciate you providing your experience on the foundational work that you’ve been doing.
Christine McPar…: Can I just expand on something that Hend said? She talked about the small, medium, large size and how we ask for that information and incorporate that information. I think that all drives back down to educating our stakeholders because there may be suppliers that can supply. So it might be a medium-size project, but we might have to have two vendors, a smaller size vendor providing some of it.
So we [00:35:00] have to educate our end users to go… It might not all be in a nice neat box. We may be awarding to multiple to allow the opportunities or to allow the foot in the door, if you will. So I think that’s a big component as well is educating the community on what we’re doing and how we’re doing it so that everybody gets that opportunity.
Barb Lima: Yeah. It sounds like that’s been the theme of today’s discussion is really the education piece, not only what we’re doing here today in terms of discussing our own experiences, [00:35:30] but also educating our internal stakeholders, our vendor communities, which I think is really pivotal and important.
And to our panelists today, our experts, thank you so much for taking the time to speak with the greater community today to share your experiences with myself and the greater community today. Here, we really encourage the idea of community and sharing our own experience is really what’s pivotal and what’s going to be making procurement better.
So for anyone out there, if you’d like any introductions [00:36:00] or further discussions with any of your panelists, please do reach out to us here at Bonfire. But again, we thank you for your time today. We thank our panelists and we hope you have a pleasant day.
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