The Procurement Policy will be reviewed every three (3) years. The next scheduled review is May, 2026. The policy may be reviewed and updated earlier should there be changes to the Ontario Public Service Procurement Directive.
(Developed in the spirit of Ontario Public Service Procurement Principles and Administrative Authority Accountability Requirements.)
1. Purpose and interpretation
2. Responsibilities
3. Scope
4. Legal and policy context
5. Principles and other considerations
6. Policy
- 6.1. Planning
- 6.1.1. Initiating procurement
- 6.2. Procurement
- 6.2.1 Procurement methods
- 6.2.2. Procurement value determination
- 6.2.3. Follow-on agreements (consecutive contracts)
- 6.2.4. Goods or services other than consulting or professional services
- 6.2.5. Consulting and professional services
- 6.2.6. Ontario Public Sector (OPS) Vendor of Record (VOR)
- 6.2.7. Internal vendor of record
- 6.2.8. Standing offers
- 6.3. Solicitation
- 6.4. Evaluation methodology
- 6.5. Failed procurements
- 6.6. Approval of successful proponent
- 6.7. Non-competitive procurements
- 6.7.1. Single or Sole source purchases
- 6.7.2. Urgent/emergency procurements
- 6.7.3. Exceptions
- 6.8. Contracts
- 6.8.1. Form
- 6.8.2. Amendments
- 6.9. Performance management
7. Document and records retention
- 7.1. Retention
1.1 The policy sets out requirements to support the efficient, timely and cost-effective procurement of goods and services on behalf of the Real Estate Council of Ontario (RECO) through a process that is competitive, fair, open, transparent, geographically neutral and accessible to qualified vendors based on principles contained in the Government of Ontario’s Procurement Directive and leading practices in the broader public, not for profit and private sectors. It is intended to outline responsibilities of RECO employees through every stage of the procurement process and to provide all RECO employees with clear guidelines consistent with leading practices. The policy supports RECO's goal of demonstrating integrity and transparency expected from RECO and its employees in all procurement-related decisions.
1.2 The following terms shall have the following meanings:
“CEO” means RECO’s Chief Executive Officer
“CFO” means RECO’s Chief Financial Officer
“Board” means the Board of Directors of the Real Estate Council of Ontario (RECO).
“Invitational procurement” means any competitive procurement process where a minimum of three qualified suppliers are invited to submit a bid, and could also include a public posting to permit others to also submit a bid (i.e. quote or proposal)
"Direct purchase” is the purchase of goods or services whereby vendors are approached directly with specific requirements for goods or services instead of posting an RFX on a public platform
“Open competitive procurement” means a process where the invitation to compete is posted publicly using a reputable online tendering system and permitting any qualified vendor to submit a bid
“ELT” means the executive leadership team at RECO, including the CEO and those appointed by the CEO.
“Directive / OPS Procurement Directive” means the Ontario Public Service Procurement Directive, as amended from time to time.
“RFX” is an acronym for a request for [X], where x stands for Information (RFI), Proposal (RFP), or Quotation (RFQ)
“Standing offer” is an agreement between RECO and a service provider regarding the rates, terms, and conditions to be applied to services that may be supplied at a future date on an “as and when required” basis
“Vendor of Record (VOR)” Vendor of Record (VOR) is a supplier that has been pre-qualified through a competitive procurement process by the Ontario government.
“Internal Vendor of Record (IVOR)” RECO maintains internal VOR arrangements established through a competitive or otherwise compliant procurement process
2.1. The CFO oversees the administration of the policy, and sets the strategic direction of RECO’s purchasing policy, in consultation with ELT and the Director, Finance & Accounting
2.2. The Director, Finance & Accounting is responsible for the administration of the Policy, and shall provide to the CFO such reports in that respect, as the CFO may require from time to time.
2.3. Any deviations from the policy are to be documented and approved by the CFO and by the CEO with copies of the approval to the accounting department.
The policy applies to the procurement of all goods and services made on behalf of RECO.
The policy is to be interpreted in line with the legal and policy framework, with the intention of adhering to relevant law and policy, including but not limited to:
Canada Not-for-Profit Corporations Act, S.C. 2009, c.23, as amended
Not-for-Profit Corporations Act, 2010 (ONCA), S.O. 2010, c.15, as amended
Trust in Real Estate Services Act, 2002 (TRESA), S.O. 2002, c. 30, Sched. C, as amended
Safety and Consumer Statutes Administration Act, 1996, S.O. 1996, c.19, as amended
The Administrative Agreement between RECO and His Majesty the King in right of Ontario as represented by the Minister of Public and Business Service Delivery and Procurement
RECO’s Policy on Delegation of Authorities
The objective of the policy is that RECO acquires the goods and services required to meet their needs in the most economical and efficient manner, through procurement processes that conform to the following principles:
Value for money
Goods and services must be procured only after consideration of RECO’s business requirements, alternatives, timing, cost, supply strategy, and procurement method.
Vendor access, transparency, and fairness
Qualified vendors must be given open access to compete for business in accordance with the policy. The procurement process must be conducted in a fair and transparent manner. Conflicts of interest, both real and perceived, must be avoided during the procurement process and any ensuing contract. Access for qualified vendors to compete for business is open and the procurement process is conducted in a fair and transparent manner, providing equal treatment to vendors. Conflicts of interest, both real and perceived, are avoided during the procurement process and the ensuing contract. Relationships that result in continuous reliance on a particular vendor for a particular kind of work are not created.
Responsible management
The procurement of goods and services must be responsibly and effectively managed through appropriate organizational structures, systems, policies, processes, and procedures.
Geographic neutrality and reciprocal non-discrimination
RECO is subject to Ontario’s Trade Agreements and must ensure that access for vendors to compete for procurement opportunities is geographically neutral with respect to other jurisdictions that practice reciprocal non-discrimination with Ontario.
Conflict of interest
All members, employees, contractors, and any individuals acting on behalf of RECO must avoid any actual, potential, or perceived conflict of interest in the performance of their duties.
A conflict of interest exists where an individual’s personal, financial, or other private interests could improperly influence, or be perceived to influence, their judgment, decisions, or actions in the course of carrying out RECO-related responsibilities.
Individuals are required to:
Failure to disclose or appropriately manage a conflict of interest may result in disciplinary action, up to and including termination of employment or contract, and may also result in further legal or regulatory consequences where applicable.
Ethical considerations
All purchases made on behalf of RECO shall be consistent with RECO's Employee Conduct policies. RECO employees involved in purchasing will discharge their duties honestly, forthrightly, objectively and with integrity. RECO employees shall not use their official capacity or company time to negotiate or conduct personal purchases for themselves or others.
Procurement integrity and non-circumvention of approval thresholds
RECO must not take any actions to reduce the value of procurements or otherwise circumvent established approval authority thresholds or competitive procurement requirements.
Such prohibited actions include, but are not limited to:
Subdividing or splitting projects, procurements, or contracts into multiple smaller components to avoid required approval levels or competitive procurement processes;
Structuring procurements in a manner that artificially reduces the estimated or actual contract value below applicable approval thresholds; and
Awarding multiple consecutive contracts to the same vendor for the same or similar deliverables where the intent is to avoid competitive procurement requirements or approval authority limits.
All procurement activities must be planned and executed in a manner that reflects the total anticipated value of goods and services over the full term of the requirement, including any foreseeable renewals or extensions.
Accessibility obligations
RECO will comply with the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) and all accessibility standards mandated by regulations made under the Act
RECO will consider facility accessibility when procuring deliverable goods and services. RECO will take all reasonable steps necessary to comply with:
Environmental, social and governance (ESG) considerations
RECO will consider the environmental and social impacts of its procurement activities in a transparent and accountable way that balances fiscal responsibility, social equity, and environmental stewardship.
Local food procurement (encouraged practice)
The Directive encourages RECO to adopt the spirit of the local food procurement policy in food purchases valued under $30,300. RECO may consider local sourcing where practical and appropriate, in alignment with value for money, operational needs, and applicable trade agreement requirements.
RECO supports this practice and may adopt these requirements where appropriate.
Ethical apparel procurement requirements (encouraged practice)
The Directive encourages RECO to adopt the ethical apparel procurement requirement for all apparel procurements estimated at or above $5,000. RECO may consider that vendors provide Responsible Manufacturers Information (RMI), including the name and address of all factories and production facilities used in the manufacture and assembly of the product, prior to signing of the agreement.
When submitting RMI, the vendor will also confirm that, to the best of their knowledge, the manufacturer and any subcontractors for the item(s) offered comply with all local laws governing labour and working conditions and will continue to do so throughout the duration of any resulting contract(s).
RECO supports this practice and may adopt these requirements where appropriate.
Requirements based
To promote a fair and competitive procurement process, all goods or services being purchased must have clearly defined requirements. If a business case is required in accordance with section 6.1.1, it should include these requirements. If research is conducted to develop these requirements, it must be done independently of potential vendors. An RFI can be used to assist with the creation of requirements, however it must be made clear that no contract will result.
Privacy and information protection requirements
Prior to undertaking any procurement of goods and/or services that may result in the collection, use, or disclosure of personal or sensitive information, RECO will conduct a risk assessment that includes a Privacy Impact Assessment and a Threat Risk Assessment. Any information collected, used, or disclosed through the procurement process will comply with applicable privacy legislation.
The policy covers all procurement activities from planning to contract negotiation outlined herein. Information regarding the administration of document and records retention is found in section 7 of the policy.
RECO must undertake procurement planning as an integral part of the procurement process to identify the goods and services needed to meet their business requirements.
Requesting Departments are to communicate their proposed annual procurement activities to the accounting department as part of the budget preparation process to ensure applicable resources are available to support the process.
Notwithstanding delegated procurement approval authorities established under this Policy and RECO’s Sub-Delegation of Authorities Policy, departments are expected to ensure appropriate communication and awareness with the applicable Executive Leadership Team (ELT) member regarding intended procurement activities.
Departments shall identify anticipated procurement requirements through the annual budgeting and operational planning process wherever feasible. Where a proposed procurement is not included within the approved budget, or may have significant operational, financial, strategic, or reputational impact, the department manager shall notify and consult with the appropriate ELT member prior to initiating the procurement process.
This requirement is intended to support organizational planning, financial oversight, and alignment with RECO’s operational priorities, and does not limit or replace delegated procurement approval authorities established under this Policy.
Requisitioning departments are to only procure goods and services within the approved department/project budget. The department manager is responsible for all procurements, but may delegate the administrative process to any knowledgeable person in the department. A business case is required for all purchases greater than $10,000 prior to commencing any procurement activities. Refer to the Policy on Sub-Delegation of Authorities for guidance on re-purposing budget if required. The business case must include clearly defined requirements to be included in the purchase request and must be approved by both the manager and the corresponding member of ELT. If the procurement method will be non-competitive, in accordance with section 6.7, the business case shall include sufficient and reasonable justification.
The need for assistance in the performance and delivery of required services, excluding Human Resources (employees or agency staff), will periodically necessitate the engagement of external service providers.
RECO shall not purchase external consulting or professional services where existing internal resources are available for the assignment, unless otherwise approved by the applicable ELT member. Managers, in consultation with Human Resources, shall identify cost-effective opportunities where outsourced work can be brought back internally using existing workforce capacity.
Departments requesting any computer-related equipment shall refer such requests to the Director, Information Technology (IT).
Departments requesting any general office supplies shall refer such requests to the Director, Human Resources or a higher-level manager.
The procurement value includes an estimate of the full aggregate costs over the total expected contract term and is exclusive of taxes. The expected contract term includes any optional extensions or renewal provisions in the agreement that may exercise without a new competitive process. No action shall be taken to reduce the value of the procurement to avoid any requirements regarding competition, approval levels or reporting.
Vendor arrangements will not exceed six (6) years (including any renewal periods) without a new competitive process, unless approved by the CEO. For single or sole source arrangements, the existing business case (which includes the justification for single or sole source) must be reviewed and updated every 6 years to assess if the facts and circumstances still apply. If not, the business case must be revised and approved by both the manager and the relevant ELT member, or a competitive process will be undertaken in accordance with section 6.2.1.
Where an invitational bid solicitation or open competitive procurement is required, the RFX issued will vary depending on the purchase.
RFQ’s are generally used when exact specifications are known where vendors will be competing solely on price. RFP’s are generally used when vendors are being asked to propose solutions to a problem or business requirements and where price is not the sole criterion. A Request for Information (“RFI”) can be issued before an RFP if the marketplace is not well understood, or a range of options are being considered.
In determining value for money, RECO will consider both costs and benefits associated with the procurement. Costs and benefits may include, but are not limited to, a comprehensive assessment of the total value of the procurement over its lifecycle, including both financial and non-financial factors such as:
Costs and benefits may include, but are not limited to:
Conferred value
RECO is responsible for determining the procurement value in order to establish the appropriate procurement approval authority and procurement method, in accordance with applicable procurement directives and policies.
Where a project involves multiple related procurements, the total procurement value shall be calculated based on the cumulative value of all related procurements.
The award of multiple consecutive contracts to the same vendor, including follow-on agreements, shall only be permitted where it is justified in accordance with the OPS Procurement Directive (Section 4.2.2 – Follow-On Agreements).
Such awards may only proceed where:
Where these conditions are not met, the procurement shall be subject to an open competitive process.
RECO is encouraged to conduct open competitive procurements for all goods and non-consulting services. However, RECO may conduct such procurements using its own policies, processes, and procedures, provided they are consistent with the principles of the OPS Directive.
Approval authorities shown below are subject to RECO’s Sub-Delegation of Authority Policy (Sub-DOA). In the event of conflict, the Sub-DOA Policy shall take precedence.
| Procurement Value | Minimum Procurement Method | RFX and business template required? | Approval authority | Minimum number of days the RFX needs to be open for response |
|---|---|---|---|---|
| $0 to less than $30,300 | Direct purchase (non-competitive procurement), ensuring value for money, or use of Vendor of Record (VOR) arrangement where applicable | No | Manager | N/A |
| $30,301 up to and including $121,200 | Invitational competitive procurement involving a minimum of three (3) qualified suppliers invited to submit written quotes or proposals, or purchase via VOR arrangement where applicable | Yes | Director | 15 calendar days |
| $121,201 up to and including $500,000 | Open competitive procurement process through publicly posted RFX, or purchase via VOR arrangement where applicable, unless a non-competitive procurement is permitted under section 4.4.4.2 (Allowable Exceptions) of the OPS Procurement Directive | Yes | Member of Executive Leadership Team | Calendar days |
| $500,001 up to and including $1,000,000 | Open competitive procurement process through publicly posted RFX, or purchase via VOR arrangement where applicable, unless a non-competitive procurement is permitted under section 4.4.4.2 (Allowable Exceptions) of the OPS Procurement Directive | Yes | 2 Members of Executive Leadership Team, OR CEO | 25 business days |
| Above $1,000,000 | Open competitive procurement process through publicly posted RFX, or purchase via VOR arrangement where applicable, unless a non-competitive procurement is permitted under section 4.4.4.2 (Allowable Exceptions) of the OPS Procurement Directive | Yes | CEO and Board Chair | 25 calendar days |
RECO may use an invitational competitive procurement process for consulting services valued at less than $121,200. An invitational competitive procurement is achieved by requesting a minimum of three (3) qualified vendors to submit a written proposal in response to the procurement requirements, in accordance with the OPS Procurement Directive.
RECO must use an open competitive procurement process for consulting services valued at $121,200 or more, in accordance with the OPS Procurement Directive.
RECO may use non-competitive procurement for consulting services only in circumstances that meet the allowable exceptions set out in Section 4.4.4.2 of the OPS Procurement Directive. All such procurements must be appropriately justified and approved in accordance with RECO’s approval authorities.
Approval authorities shown below are subject to RECO’s Sub-Delegation of Authority Policy (Sub-DOA). In the event of conflict, the Sub-DOA Policy shall take precedence.
| Procurement Value | Minimum Procurement Method | RFX and business template required? | Approval authority | Minimum number of days the RFP needs to be open for response |
|---|---|---|---|---|
| $0 to less than $121,200 | Invitational competitive procurement may be used for consulting services, where permitted under the OPS Procurement Directive, by inviting a minimum of three (3) qualified vendors to submit written proposals. VOR arrangements may be used where applicable in accordance with applicable VOR usage requirements | Yes | Director and Member of Executive Leadership Team | 15 calendar days |
| $121,201 up to and including $500,000 | Open competitive procurement process through publicly posted RFX, or purchase via VOR arrangement where applicable, unless a non-competitive procurement is permitted under section 4.4.4.2 (Allowable Exceptions) of the OPS Procurement Directive | Yes | Member of Executive Leadership Team | 25 calendar days |
| $500,001 up to and including $750,000 | Open competitive procurement process through publicly posted RFX, or purchase via VOR arrangement where applicable, unless a non-competitive procurement is permitted under section 4.4.4.2 (Allowable Exceptions) of the OPS Procurement Directive | Yes | 2 Members of Executive Leadership Team, OR CEO | 25 calendar days |
| Above $750,000 (Consulting Services) | Open competitive procurement process through publicly posted RFX, or purchase via VOR arrangement where applicable | Yes | CEO and Board Chair | 25 calendar days |
A competitive procurement process must be used for consulting services, regardless of value, except where a non-competitive procurement is permitted in accordance with section 4.4.4.2 (Allowable Exceptions) of the OPS Procurement Directive, as amended from time to time.
RECO may use an invitational competitive procurement process for consulting services valued up to $121,200. An invitational competitive procurement is achieved by requesting a minimum of three (3) qualified vendors to submit a written proposal in response to the procurement requirements, in accordance with the OPS Procurement Directive.
RECO is a registered non-OPS client under the Ministry of Public and Business Service Delivery and Procurement’s VOR arrangement.
Where VORs have been established, RECO will consider leveraging the VOR to negotiate better pricing for any relevant procurements. Where three bids are required, vendors may be solicited from the VOR list.
RECO must comply with the VOR arrangement terms of use prior to accessing VOR arrangements. When using a VOR arrangement, RECO must refer to the applicable VOR User Guides issued by the Ministry of Public and Business Service Delivery and Procurement.
In addition to any mandatory Vendor of Record (VOR) arrangements established through Supply Ontario, RECO maintains internal VOR arrangements for specific goods and services.
Where an internal VOR is in place, employees must procure the applicable goods or services through the designated internal VOR vendor(s), unless an approved exception is obtained in advance in accordance with this policy.
Internal VOR arrangements:
Where both a Supply Ontario VOR and an internal VOR exist for the same category:
The Supply Ontario VOR shall take precedence unless the internal VOR has been formally approved as an exception or provides a justified best value in accordance with applicable procurement directives.
RECO may establish standing offer arrangements for specialized consulting or professional services required on an ad hoc or as-needed basis where it is operationally beneficial to pre-qualify vendors in advance.
A standing offer is a non-binding arrangement between RECO and one or more qualified vendors that establishes predetermined rates, terms, and conditions for the provision of specified services during a defined period. Standing offers shall be established through an open, fair, and transparent procurement process in accordance with this Policy.
The standing offer arrangement shall specify:
Where services are required under a standing offer, vendor selection shall be based on a documented process that may include rotational assignment, secondary selection, expertise, availability, performance, or best value considerations, as applicable to the specific requirement.
All assignments issued under a standing offer must:
The establishment of a standing offer does not guarantee any minimum volume of work to vendors. RECO reserves the right to conduct a separate procurement process where it is determined to be in the best interest of the organization.
In developing procurement documents, RECO is encouraged, as appropriate, to consider the principles reflected in the Ontario Public Service Procurement Directive. These requirements include, but are not limited to, providing a clear description of the required goods or services in generic and/or functional terms, full disclosure of evaluation criteria and process, and any conditions for obtaining procurement documents such as confidentiality agreements.
RECO is encouraged to use, at a minimum, the bid response times set out in this Policy. These timelines include a minimum of 15 calendar days for procurements valued up to $121,200 and a minimum of 25 calendar days for procurements valued greater than $121,200, which may be reduced to 20 calendar days where a notice of planned procurement is issued more than 40 days and up to 12 months in advance of the intended procurement.
RECO supports this practice and may adopt these requirements where appropriate.
All open competitive procurement of good and services will be posted publicly using a reputable online tendering system. Managers are responsible for ensuring that substantive deviations from standard RFX templates are reviewed by RECO legal counsel. For confidential solicitations, vendors must first sign a Confidentiality & Non-Disclosure Agreement.
From the time the RFX is released until the submission deadline, RECO is prohibited from contacting individual vendors. Any inquiries from vendors must be responded to publicly to create an unbiased knowledge base that is consistent for all vendors.
Managers, in consultation with the Director, Finance & Accounting, will set out the evaluation process and criteria. For competitive processes, the evaluation criteria will be clearly outlined in the RFX. When determining and documenting evaluation criteria for the procurement, the manager shall:
For all purchases greater than $30,000, Managers, in consultation with the Director, Finance & Accounting, will also form a suitable evaluation team of at least 3 members. Each evaluation team member will sign off on the final scoresheets once complete.
Bids not received by the deadline must be returned.
Once all bids have been received, the person responsible for the RFX must ensure that each member of the evaluation team independently scores each response. The scores will be collated by the responsible person, and the evaluation team will convene to discuss the scoring and create a shortlist of vendors. The shortlisted vendors will be interviewed using a standardized format and set of questions to achieve a level playing field. After the interviews, the evaluation will meet again to share scores and select only the highest ranked submission(s) that have met all mandatory requirements set out in the related procurement document.
RECO has the right to cancel any RFX, at its sole discretion, at any time during the procurement process. This fact is to be included in all RFX documentation.
All bids are evaluated consistently, according to the evaluation methodology documented and communicated to potential proponents, and the highest ranked proponent is selected. The individual responsible for the RFX will notify the highest ranked proponent, and initiate negotiations in order to finalize a contract. Unsuccessful proponents should only be informed once a contract with the successful vendor has been executed.
Managers will make certain that the selection of the successful proponent is approved in accordance with the authorization of contract parameters of RECO’s Sub-delegation of Authorities Policy.
Single source means the use of a non-competitive procurement process to acquire goods or services from a specific supplier even though there may be more than one supplier capable of delivering the same goods or services.
Sole source means the use of a non-competitive procurement process to acquire goods or services from a specific supplier because there are no other suppliers available or able to provide the required goods or services. RECO may, at its discretion, choose to align sole source procurements with the renewal cycle of the OPS VOR arrangements.
RECO policy is to avoid single or sole source purchases wherever possible.
Where a non-competitive procurement is required due to an unforeseeable situation of urgency, the procurement process can be accelerated with approval from the applicable ELT member.
An unforeseen situation of urgency does not occur where RECO has failed to allow sufficient time to conduct a competitive procurement process.
Any exceptions to the requirements of this Policy must be documented, justified, and approved by the appropriate Executive Leadership Team (ELT) member prior to proceeding with the procurement. All approved exceptions must include a written rationale and supporting documentation demonstrating the business need and compliance considerations.
Exceptions may be considered only in limited circumstances, including but not limited to:
Exceptions must not be used to circumvent competitive procurement requirements or established approval authority thresholds.
Funds received and administered by RECO in a trustee or custodial capacity, including unclaimed or dormant trust funds remitted by brokerages, are excluded from the scope of this Procurement Policy.
Contracts must be written in the name of RECO and prepared using RECO's standard forms, unless otherwise authorized by RECO legal counsel. Legal counsel must review all contracts to ensure compliance with RECO policies and applicable laws. Confidential information about RECO, its registrants, customers, clients, suppliers, or employees shall not be divulged to anyone other than persons who are authorized to receive such information. A confidentiality agreement/provision will form part of a contract that is entered into between RECO and a vendor when it is necessary to maintain the confidentiality and integrity of the process.
Procurement documents, including the agreement, must include the framework under which price increases will be permitted. This framework must specify, at a minimum:
In the event of a contract extension due to an increase in the scope of work or other contractual terms, the manager shall prepare a decision note to all affected parties outlining the reasons for the scope change and obtain all necessary additional approvals. All increases in cost are to be approved by the appropriate ELT member. A copy of the amendment shall be forwarded to the accounting department.
In alignment with the OPS Procurement Directive, RECO must ensure that the appropriate procurement method and corresponding approval authority are applied based on the revised procurement value. This requirement applies at the time of the value increase, particularly where the revised procurement value exceeds the approval threshold of the original approver.
Once a contract has been executed, the manager will be responsible for monitoring vendor performance to ensure all work is completed within the terms and conditions of the contract.