Corruption in Quebec’s construction industry: cleaning the Augean stable

Construction Law International homepage  »  November 2019



Sharon Vogel
Singleton Urquhart Reynolds, Toronto, Ontario
Emira Bouhafna
Singleton Urquhart Reynolds, Toronto, Ontario


In Canada, the Province of Quebec has been the focus of investigation in relation to corruption on construction projects. In October 2011, a public inquiry (the ‘Charbonneau Commission’) was established, led by Justice France Charbonneau. The Charbonneau Commission found that corruption pervaded the Quebec construction industry and made 60 recommendations to the Quebec government aimed at increasing oversight of the industry and enhancing investigative and enforcement mechanisms. This article provides a brief overview of Canada’s legislative regime in respect of bribery and corruption, summarises some of the key findings of the Charbonneau Commission and analyses the legislation introduced to date to implement the Charbonneau Commission’s recommendations. Corruption in the construction industry is not a problem unique to Quebec, and some of the solutions implemented there can serve as a model for other jurisdictions both inside and outside Canada.



Corruption is a global phenomenon with serious repercussions for governments, their economies and communities. In many jurisdictions, efforts to curb corruption have increased significantly over the past two decades, albeit with mixed success.1 It is likely that globalisation and the loosening of international trade barriers have led to a heightened awareness of the pervasiveness of corruption on the global stage and its serious consequences on developing economies in particular. However, corruption is not a phenomenon that is confined to developing economies: Transparency International’s 2017 Corruption Perceptions Index shows a high level of corruption in more than two-thirds of the 180 countries surveyed.2 The most recent Foreign Bribery Report issued by the Organisation for Economic Cooperation and Development (OECD) contains some telling findings.3 The OECD found that the construction sector is one of the four sectors most affected by corruption and its associated risks: ‘two thirds of the foreign bribery cases occurred in four sectors: extractive (19%); construction (15%); transportation and storage (15%); and information and communication (10%)’.4

This article seeks to provide insight into the Canadian experience of fighting corruption in the construction industry. First, we provide an overview of the legislative framework applicable to Canadian companies involved in construction projects abroad and to foreign and Canadian companies involved in construction projects in Canada. Next, we examine the Canadian Province of Quebec, where a spate of corruption scandals involving the construction industry led to a public inquiry: the Charbonneau Commission of Inquiry.5 After summarising some of the key findings and recommendations of the Charbonneau Commission, we describe the legislative developments that have ensued.

Canadian companies and individuals involved in a construction project in a foreign jurisdiction can be charged and prosecuted in Canada under the CFPOA.

The legislative framework

Canadian companies engaged in construction projects abroad

Pursuant to the OECD Convention on Combating Bribery of Public Officials in International Business Transactions,6 Canada enacted the Corruption of Foreign Public Officials Act (CFPOA),7 which entered into force on 14 February 1999. The CFPOA features two offences: (1) bribing a foreign public official; and (2) accounting and record-keeping fraud. The CFPOA applies to all businesses and individuals that engage in corrupt practices with ‘foreign public officials’, defined as persons holding legislative, administrative or judicial positions in a foreign state; persons performing public duties or functions in a foreign state; and officials or agents of public international organisations.8

Under the CFPOA, it is an offence to bribe a foreign public official to obtain an advantage, whether or not the bribe is paid or the advantage is obtained. In addition, it is an offence both to offer and accept a bribe. In addition, under the CFPOA, accounting offences include forging accounting records and destroying records so as to conceal the bribery of a foreign public official.

Canadian companies and individuals involved in a construction project in a foreign jurisdiction can be charged and prosecuted in Canada under the CFPOA and therefore should be cautious when operating in markets with higher risks of corruption.9

Foreign and Canadian companies engaged in construction projects in Canada

Foreign and Canadian companies operating in Canada are subject to the bribery and corruption offences in Canada’s Criminal Code (the ‘Code’).10 Among other corruption-related offences, the Code criminalises the bribery of judges,11 members of parliament,12 government officials,13 municipal corruption,14 fraud15 and private sector bribery.16 Particularly noteworthy are the provisions that specifically address bribery to obtain government contracts by withdrawing one’s tender or having another entity withdraw its tender.17

Canadian courts have held that the sentencing principles of denunciation and general deterrence are the most important objectives in sanctioning corruption offences, and the absence of an upper limit on the fines that the court can impose means that companies can be subject to hefty fines.18

Debarment for corruption offences

A serious consequence of conviction for corruption offences under both the CFPOA and Code provisions is the risk of being disqualified from bidding on government contracts. In July 2012, Public Works and Government Services Canada (now Public Services and Procurement Canada) added the offence of bribing a foreign public official under the CFPOA to the list of offences that render companies and individuals ineligible to bid for Canadian government contracts, and in 2014 the list was expanded to include foreign convictions for equivalent offences.19

The Quebec construction industry and the Charbonneau Commission of inquiry

Background to the Charbonneau Commission

In the 1990s and 2000s, a number of highly publicised corruption-related scandals shook Quebec and flooded Canadian media.20 Leading up to the creation of the Charbonneau Commission, notable scandals included: allegations of a price-fixing scheme orchestrated by 14 construction companies using a gang (known as the Hells Angels) to intimidate competitors; bribery in the awarding of construction contracts in the city of Montreal through kickbacks to political parties, councillors and city bureaucrats; and infiltration of the construction industry by organised crime.21

Creation and mandate of the Charbonneau Commission

The Charbonneau Commission was created on 19 October 2011 by the provincial government of Quebec and was chaired by Quebec Superior Court Justice France Charbonneau. Its mandate was threefold:
(1) to inquire into the existence of schemes that may have involved activities of collusion and corruption in the awarding and management of public contracts in the construction industry, including possible connections to the financing of political parties;
(2) to explore the possible infiltration of organised crime into the construction industry; and (3) to examine potential solutions and to make recommendations aimed at establishing measures to identify, eliminate and prevent collusion and corruption in the awarding and management of public contracts in the construction industry, as well as infiltration of the construction industry by organised crime.22

The Charbonneau Commission heard from approximately 300 witnesses over 263 days of hearings and cost taxpayers close to C $45m.23 The Charbonneau Commission delivered its voluminous report (1,741 pages) on 24 November 2015. It found that corruption and collusion permeated the Quebec construction industry, and made 60 recommendations to the Quebec Government. Below is a summary of some of the Charbonneau Commission’s key findings.

A serious consequence of conviction for corruption offences under both the CFPOA and Code provisions is the risk of being disqualified from bidding on government contracts.

Types of schemes identified by the Charbonneau Commission

The Charbonneau Commission defined collusion as a secret agreement, implicit or tacit, between private sector actors (contractors, consulting engineering firms and suppliers) responding to a public call for tenders or in some cases, an invitation to bid, with a view to reducing or eliminating competition to gain control over a public contract. It defined corruption as situations in which private actors obtain benefits (contract, payment of extras and confidential information) from public actors within the administrative or political apparatus. In exchange for the advantage provided to the ‘corrupter’, the ‘corrupted’ receives consideration that can take various forms (bribes, employment, favours, gifts, etc).24

The Charbonneau Commission identified three categories of schemes in Quebec’s construction industry.

1. Schemes involving collusion and corruption;25

(i) simple collusion-based schemes, which involved:

• colluders rotating successful bidders among themselves, by having others submit ‘soft’ bids (also referred to as ‘cover’, ‘courtesy’ or ‘complementary’ bidding);

• colluders rotating successful bidders by having other colluders not submit bids;

• the winning firm agreeing to subcontract to other colluders;

• colluders dividing the market (by type of work, client and geographic area) and agreeing not to bid competitively in other markets; and

• preventing competitors outside the cartel from participating in procurement through various schemes, such as intimidation, vandalism or sabotage on the competitor’s job sites, and bidding very low to prevent the competitor from winning contracts;

(ii) simple corruption-based systems, which involved;

• political corruption: for example, a firm would finance a specific municipal candidate’s election to obtain quasi-exclusivity on municipal contracts after the election;

• bureaucratic corruption: a bureaucrat or other member of the public service is corrupted, for example;

– agreement to provide the appointed or elected official with a specific kickback on the amount of the contract, as well as various gifts;

– officials influencing proposal/bid criteria so as to benefit a particular firm through directed tendering schemes; and

– officials manipulating the composition of selection committees by adding people in favour of a particular firm;

• private corruption: private actors (contractors) were found to charge a public contracting authority for work that had not been performed, or for quantities of material not used, while private engineering firms responsible for contract administration would approve false quantities or false extras;

(iii) complex schemes, which combined both collusion and corruption practices, were mainly observed in large cities (eg, Montreal) where the larger political and administrative machinery of government require a combination of collusion and corruption to maintain successful schemes and cartels; the report confirmed that elected officials and public employees played a central role in protecting against the detection of complex schemes;

2. schemes linked to the financing of political parties;26

• the Commission found that links between financing of political parties and awarding of public contracts were both direct and indirect: direct links included schemes in which a specific private benefit was given to an official in exchange for a specific contract (most often seen in Quebec municipal politics), while indirect links included schemes in which private parties provided general support in exchange for some general advantage to be awarded at a later date;

3. schemes involving activities by organised crime;27 the Charbonneau Commission identified four main types of infiltration by organised crime:

(i) infiltration of companies and industry sectors: where businesses in financial difficulty acquired sources of financing from criminal organisations, which eventually took over the company for their own purposes (including money laundering);

(ii) control of territories: where criminal organisations controlled a sector or territory by using intimidation and violence;

(iii) intimidation services: where organised crime groups assisted businesses in their schemes by intimidating other firms or businesses in the market; and

(iv) access to trade union investment capital: where individuals linked to the Hells Angels and the Mafia sought to infiltrate the industry by obtaining access to the capital investments of a construction union.

Causes of corruption and collusion identified by the Charbonneau Commission28

The Charbonneau Commission identified the following as salient causes of corruption and collusion in Quebec’s construction industry:

1. the vulnerability of the public procurement of construction contracts to corruption due to the large amounts involved;

2. the lack of expertise of the public bodies involved in procurement, and the use of certain processes that facilitate collusion (eg, non-negotiable tariff contracts);

3. the foreseeability of criteria for awarding public contracts, which fosters collusion and the creation of cartels;

4. unreasonably short deadlines for tenders set by corrupt public authorities, which reduces competition and benefits a bidder with privileged or inside information;

5. the lack of regulation of selection committees, which allows for conflicts of interest and undue interference in the decision-making process; and

6. the disclosure of certain information by public authorities, which increases vulnerability to illegal schemes (eg, the release, upon request, of the list of contractors who obtained specifications or tendering documents which facilitates collusion among groups of firms).

Increase sanctions for construction companies that break the law, up to and including cancelling their licence issued under Quebec’s building authority



Select recommendations of the Charbonneau Commission in relation to key issues

As aforementioned, the CharbonneauCommission made 60 recommendations to the Quebec government.29 The following is a brief overview of certain recommendations on key issues:

1. create an independent public procurement authority to oversee public contracts:30

the authority would be a ‘centre of expertise’ that would analyse and verify procurement processes, and support and oversee all public bodies that award contracts; the Charbonneau Commission further recommended that the various public authorities be allowed to consolidate their internal expertise in construction matters;

2. standardise laws and regulations so as to allow public contracting authorities to decide, in cooperation with the public procurement authority and under its supervision, the appropriate weighting of price and quality criteria in the public procurement process for a construction contract;31

3. reduce payment delays in the construction industry because payment delays create a breeding ground for corruption and collusion; specifically, the Charbonneau Commission found that payment delays:32

• confer significant power on site supervisors, who can speed up or slow down approval of payments to intimidate or favour contractors (leading to private corruption schemes);

• restrict contractors’ ability to take on new projects and thereby contribute to restricting competition and facilitate the creation and continuation of collusive agreements; and

• lead to ‘alternative’ sources of financing – as the Charbonneau Commission noted, payment delays favour ‘infiltration of the construction industry by organized crime. A [contractor] faced with financial difficulties arising from excessive accounts receivable may be tempted to resort to sources of non-traditional financing. In fact, that is exactly what happens. Non-traditional financing is used by a significant proportion of construction firms as a result of payment delays’;33

4. increase sanctions for construction companies that break the law, up to and including cancelling their licence issued under Quebec’s building authority;34

5. increase penalties for those who make use of so-called straw man schemes;35

6. implement rules in relation to the share ownership of construction companies;36

• lower the share ownership threshold from 20 per cent to ten per cent in order for any shareholder to be considered an officer of a corporation, and attract scrutiny as to the company’s integrity; and

• empower Quebec’s building authority to assess the integrity of officers who hold shares indirectly in any contracting firm;

7. engineers and consulting engineers firms;37

• amend the Professional Code so that firms operating in the construction industry are subject to regulatory power and sanctions, and increase the role and powers of the regulatory body for engineers in Quebec; and

• implement mandatory ethics training and measures to increase compliance;

8. require public contracting authorities to report acts of intimidation or violence to the Charbonneau Commission de la construction du Québec, and amend the Act respecting labour relations, vocational training and workforce management in the construction industry to help to combat intimidation in the construction industry;38 the Charbonneau Commission found that acts of intimidation and violence had caused certain construction companies to avoid certain regions or certain types of construction contracts, which reduced competition and facilitated collusion, corruption and infiltration by organised crime; and

9. provide better protection for whistleblowers so as to encourage reporting;39

• the Charbonneau Commission found that reporting by individuals with direct knowledge of and involvement in corruption schemes was fundamental to fighting corruption: investigations are much less likely to be initiated without initial reporting of malfeasance and much less likely to succeed without the collaboration of participants in the scheme; and

• accordingly, the Charbonneau Commission recommended that a general whistleblower protection system be implemented so as to ensure anonymity for all whistleblowers, regardless of the agency to which they report and provide greater assistance to whistleblowers, particularly financial support when required.

Legislation enacted pursuant to the Charbonneau Commission’s recommendations

It was estimated at the time of the report’s release in 2015 that 80 per cent of the 60 recommendations would require legislative or regulatory amendments.40 On 8 December 2017, the Quebec government announced that more than 80 per cent of the Charbonneau Commission’s recommendations had been realised or were in the process of being implemented.41 To date, the Quebec legislature has passed nine pieces of legislation aimed at giving effect to the Charbonneau Commission’s recommendations:42

1. Bill 26, an Act to ensure mainly the recovery of amounts improperly paid as a result of fraud or fraudulent tactics in connection with public contracts, was enacted in April 2015, that is, prior to the delivery of the Charbonneau Commission’s report, but in response to concerns raised by the Charbonneau Commission. The Act provides measures for the recovery of amounts paid due to fraud in connection with all public contracts, not only those within the construction industry. It created a voluntary reimbursement programme (VRP), pursuant to which an individual or corporation could repay amounts improperly received during the course of a public project and obtain a release from the affected public body. The VRP came into effect on 2 November 2015 and closed on 15 December 2017. A failure to voluntarily report fraud may result in civil litigation for the recovery of the defrauded amount(s). The Act establishes a presumption that any entity that has participated in fraud in the procurement process is presumed to have caused injury to the public body concerned.43

2. Bill 83, an Act to amend various municipal-related legislative provisions concerning such matters as political financing, introduces tighter audit rules applicable to municipalities with more than 100,000 residents.44

3. Bill 87, an Act to facilitate the disclosure of wrongdoings within public bodies, aims to facilitate employee disclosure of wrongdoings within public bodies.45

4. Bill 98, an Act to amend various legislation mainly with respect to admission to professions and the governance of the professional system, is aimed at strengthening governance, ethics and reporting of wrongdoing in professional orders.46

5. Bill 101, an Act to give effect to the Charbonneau Commission’s recommendations on political financing, broadens the scope of investigations of illegal political financing.47

6. Bill 107, an Act to increase the jurisdiction and independence of the Anti-Corruption Commissioner and the Bureau des enquêtes indépendantes and expand the power of the Director of Criminal and Penal Prosecutions to grant certain benefits to cooperating witnesses, broadens the mandate of Quebec’s anti-corruption unit and increases its powers.48

7. Bill 108, an Act to facilitate oversight of public bodies’ contracts and to establish the Autorité des marchés publics (AMP), is a direct response to the Charbonneau Commission’s recommendation that Quebec enact a public procurement authority to ensure the integrity of public procurement in Quebec and proposes the establishment of the AMP as a central authority overseeing public contracts. This authority would take over the role of the Autorité des marchés financiers (the securities regulator in Quebec, which has the power to license businesses wishing to enter into public contracts in the province) in respect of public contracts and would oversee all other contracting processes determined by the government.49

8.  Bill 152, an Act to amend various labour-related legislative provisions mainly to give effect to certain Charbonneau Commission’s recommendations, responds to the recommendations around decreasing violence and intimidation in Quebec’s construction industry.50

9. Bill 162, an Act to amend the Building Act and other legislative provisions mainly to give effect to certain Charbonneau Commission recommendations, is aimed at increasing the power of Quebec’s building authority around the issuing of licences for contractors under the Building Act.51



Analysis and conclusion

Many of the recommendations of the Charbonneau Commission align with the principles formulated in 2009 by the OECD in respect of achieving integrity in public procurement and the Charbonneau Commission’s recommendations as a whole reflect the OECD’s view that governments must develop tools to prevent corruption throughout the entire procurement cycle, and not merely the contract formation stage.52 Indeed, the Charbonneau Commission’s recommendations are formulated around five goals that reflect an attempt to take as comprehensive and broad an approach to the issue of corruption in the construction industry as possible. These are: (1) review the framework for the awarding and management of public contracts; (2) improve prevention and detection activities and strengthen sanctions; (3) protect political party financing from influence; (4) promote citizen participation; and (5) renew confidence in elected officials and public servants.

Critics have expressed the view that the various bills enacted by the Quebec government are not getting to the root of the problem or that some aspects of the bills aforementioned undermine their stated purpose.53 For instance, the whistleblower legislation established a Public Protector to whom information may be disclosed confidentially. However, in order to disclose that information publicly and attract the protection against reprisals provided under the legislation, the whistleblower must have ‘reasonable grounds to believe that a wrongdoing committed or about to be committed poses a serious risk to a person’s health or safety or to the environment’.54 However, other bills have been well received, including Bill 108, which creates a central authority for public procurement in Quebec. This legislation is expected to reinforce the oversight of public contracts and increase the level of transparency in the tendering and awarding processes for public contracts.55

Although it has yet to be seen whether the above legislative enactments will have the intended effect on the Quebec construction industry, it seems fair to say that the Quebec government has expended significant effort to follow through with the Charbonneau Commission’s recommendations, and it will be interesting to see the extent to which corruption risk is lessened as a result.

Legislation is expected to reinforce the oversight of public contracts and increase the level of transparency in the tendering and awarding processes for public contracts.



1 Transparency International (a non-profit, non-governmental organisation dedicated to fighting corruption) contains a wealth of information on corruption around the world, including country-specific reports outlining recent developments in respect of legislative enactments and enforcement actions accessed 2 June 2018.

2 See accessed 2 June 2018.

3 OECD, OECD Foreign Bribery Report: An Analysis of the Crime of Bribery of Foreign Public Officials (OECD Publishing, 2014) accessed 2 June 2018.

4 Ibid, 10.

5 The Charbonneau Commission is officially called the Charbonneau Commission of Inquiry on the Awarding and Management of Public Contracts in the Construction Industry.

6 OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (17 December 1997) entered into force 15 February 1999 accessed 24 June 2019.

7 SC 1998, c 34 accessed 2 June 2018.

8 CFPOA n 8 above at s 2 (Definitions), s 3 (the offence of bribing a foreign public official) and s 4 (the accounting offences). The CFPOA uses the Canada’s Criminal Code definition of ‘person’, thus providing for corporate liability under the act.

9 Both the bribery offences and accounting offences carry a maximum penalty of 14 years’ imprisonment, and there is no upper limit on the fines that can be imposed in relation to offences under the CFPOA.

10 RSC 1985, c C-46 accessed 2 June 2018.

11 See n 11 above at s 119(1).

12 See n 11 above at s 119(1).

13 See n 11 above at ss 121(1)(a), (b), (c) and (e).

14 See n 11 above at s 123.

15 See n 11 above at ss 121(1)(d) and (e).

16 See n 11 above at s 426.

17 See n 11 above at ss 121(1)(f) and 121(2).

18 The sentencing principles are found in s 798 of the Code, see n 11 above. In R v Serre (2013 ONSC 1732), for instance, Justice Aitken stated (at paras 28–29): ‘[i]t is well established that, in cases… involving breach of trust by a public official, the most important objectives are general deterrence and denunciation... It has been held in numerous cases that breach of trust by a public official generally calls for a custodial sentence, even where there are significant mitigating factors.’

19 Public Services and Procurement Canada (PSPC) is the federal ministry responsible for procuring goods and services on behalf of departments and agencies of the Government of Canada accessed 11 June 2018. PSPC is also responsible for implementing the federal government’s debarment policies. Under PSPC’s current ‘Integrity Regime’, the debarment period can be up to ten years accessed 11 June 2018.

20 Eg, see Martin Patriquin, ‘Quebec: the most corrupt province’, Maclean’s (Toronto, 24 September 2010) accessed 4 June 2018.

21 See n 21 above.

22 Quebec, Rapport final de la Commission d’enquête sur l’octroi et la gestion des contrats publics dans l’industrie de la construction (Montreal: CEIC, November 2015), vol 1, pt 1, c 2, ‘Le mandat, les pouvoirs, et les obligations de la Commission’ at 12. accessed 2 June 2018. The official report is currently only available in French, but an English translation of vol III, which contains the Charbonneau Commission’s findings and recommendations, was produced by the International Centre for Criminal Law Reform and Criminal Justice Policy at the University of British Columbia Peter A Allard School of Law accessed 2 June 2018.

23 See n 23 above vol 1, pt 2, ‘Mot de la présidente’ (PDF at 16).

24 See n 23 above vol 1, pt 2, c 6 at 165–167.

25 See n 23 above vol 3, pt 4, c 1 at 4–10.

26 See n 23 above vol 3, pt 4, c 1 at 10–13.

27 See n 23 above vol 3, pt 4, c 1 at 14–17.

28 See n 23 above vol 3, pt 4, c 2 at 20–72.

29 See n 23 above vol 3, pt 5, c 2 at 91–193.

30 Recommendation no 1, see n 23 above vol 3 pt 5, c 2 at 91–97.

31 Recommendation no 2, see n 23 above vol 3 pt 5, c 2 at 97–99.

32 Recommendation no 15, see n 23 above vol 3 pt 5, c 2 at 121–122.

33 See above n 33.

34 Recommendations nos 10 and 11, see n 23 above vol 3, pt 5, c 2 at 114–117.

35 Recommendation no 13, see n 23 above vol 3, pt 5, c 2 at 118–119.

36 Recommendation no 12, see n 23 above vol 3, pt 5, c 2 at 117–118. Quebec’s building authority, the Régie du bâtiment du Québec, enacts construction, safety and professional qualification standards and oversees enforcement through investigations and inspections.

37 Recommendations no 28, 29 and 30, see n 23 above vol 3, pt 5, c 2 at 138–141.

38 Recommendations no 16, 17 and 18, see n 23 above vol 3, pt 5, c 2 at 138–141.

39 Recommendation no 8, see n 23 above vol 3, pt 5, c 2 at 109–111.

40 Parti libéral du Québec, Annonce Gouvernementale, ‘Creating the base for a new Quebec’ (8 December 2017) accessed 4 June 2018.

41 See n 33 above.

42 Of the nine bills, seven have already come into force, two were assented to 31 May 2018 and the coming into force date is not available as of the writing of this article.

43 SQ 2015, c 6. under s 47, the Minister of Justice must report to the Quebec government on the programme’s implementation within six months of the programme’s end. The report must include the names of the companies and individuals who participated in the programme, the names of the public bodies involved and the total amount reimbursed.

44 SQ 2016, c 17.

45 SQ 2016, c 34.

46 SQ 2017, c 11.

47 SQ 2016, c 18.

48 SQ 2018, c 1.

49 SQ 2017, c 27.

50 SQ 2018, c 12.

51 SQ 2018, c 13.

52 Sarah Chaster, ‘Public Procurement and the Charbonneau Commission: Challenges in Preventing and Controlling Corruption’ (2018) 23 Appeal 121 at 142–147.

53 Andy Riga, ‘Charbonneau Report: One Year Later, Has Anything Changed in Quebec?’ Montreal Gazette (Montreal, 23 November 2016) accessed 11 June 2018.

54 See n 46 above at s 7.

55 See n 52 above at 141.


Sharon Vogel is a partner at Singleton Urquhart Reynolds in Toronto and can be contacted at Emira Bouhafna is a legal counsel at Metrolinx in Toronto and can be contacted at


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