Legal References
Public Sector Accountability Act (2010)
Related References
Broader Public Sector (BPS) Procurement Directive, Ministry of Finance
Board Policy 3003 – Trustee Professional Development Expenses
Board Policy 4005 – Procurement
Board Policy 4018 Fraud Management
Board Policy 5009 – Travel, Meals and Hospitality Expenditures – Staff
Administrative Procedure 4360 – Principles of Business Conduct For Board Employees
Administrative Procedure 4315 – Fraud Management
Administrative Procedure 4380 – Travel, Meals and Hospitality Expenditures
Administrative Procedure 4400 – One-Over-One Approvals
Administrative Procedure 4570 – Procurement
Effective Date
November 29, 2010
Revisions
March 9, 2020, February 8, 2021, December 9, 2024

1. Purpose

1.1 Segregation of duties and the delegation of authority are essential controls within the porcure-to-pay process. Together, they ensure process integrity of the process by reducing exposure to inappropriate, unauthorized or unlawful expenditures.

2. Definitions

2.1 “Contract” – Includes any written or oral agreement, contract, subcontract, letter of intent, memorandum of understanding, memorandum of agreement, lease, deed, offer, grant, license, purchase order, invoice, certificate, instrument, assignment, or any other document which creates a responsibility, right or benefit of which may be binding on the WRDSB; this may include both monetary and non-monetary  value. 

2.2 “Dollar Threshold” – represents the maximum monetary value of the contract for approval and/or signing authority. All thresholds are in Canadian pre-tax dollars and are based on the cumulative value of the contract over its full term (including specified options, renewals or extensions). 

2.3 “Signing Authority” – Identifies the individual(s) within WRDSB with authority to review, recommend and sign a contract that commits WRDSB to a legal relationship and contractual obligations or benefits. Individuals with signing authority are set out in Section 3.0 of this policy. Individuals with designated signing authority have authority to sign any approved contract up to the maximum approved dollar threshold as set out in this policy. 

3. Application

3.1 Segregation of duties prevents any one person from controlling the entire procure-to-pay process by segregating approvals for the key stages of the process.

3.2 The Waterloo Region District School Board (WRDSB) will segregate a minimum of three (3) of the following five procurement roles below:

Function Responsibility Accountable Party
Requisitioning Authorize procurement services to place an order Requisitioner
Requisition Approval Authorize that funding is available to cover the cost of the requested order, and that the requested items/services are required Budget Holder
Purchase Order Authorize release of the order to the vendor under agreed terms Procurement Services
Receiving Authorize that the order was physically received, correct and complete Individual Receiving The Goods/Services
Payment Authorize release of payment to the vendor Accounts Payable

3.3 Approvals Authority Schedule (AAS)

The following tables identify the approvals required for various levels of operating and capital procurement activities. These authority levels shall be adhered to by all WRDSB personnel.

Approvals for all procurement expenditures must be based on the total estimated value, inclusive of taxes and any agreed upon renewals.

3.4 Contract Signing Authority

All contracts, letters of intent or agreements shall be reviewed and signed by authorized signatories of the WRDSB only.  These include the Director of Education, the Coordinating Superintendent, Business Services & Treasurer of the Board, or the Manager of Procurement Services.

In circumstances where a contract is required for a one-time event, such as reserving a banquet hall for graduation, or to book a guest speaker, an exception exists whereby a Superintendent, Principal or Manager may sign the contract; to a maximum of $10,000. No other staff shall commit to any contractual agreement.

3.2 Electronic Requisition Approval Authority Schedule

Note: Technology equipment or facilities related items may require additional operational (non-monetary) approvals from the appropriate department (Information Technology Services, Facility Services) prior to procurement.

Total Purchase Amount Delegated Authority level
Less than or equal to $50,000 Principal/Manager
Less than or equal to $100,000 Associate Directors, Superintendents, Controllers, Executive Managers, Senior Managers
Greater than $100,000 Superintendent of Business Services and Treasurer of the Board, or Director of Education
EXCEPTIONS:
Less than or equal to $1,000,000 Computer Hardware & Software Executive Manager of IT & Digital Transformation (CIO)
Less than or equal to $1,000,000 Facilities Maintenance & Construction Projects Superintendent of Facility Services, or Manager of Capital Projects

Note: The exceptions identified in 3.5 exist to ensure consistency with established WRDSB technology and building standards, as well as compliance with any existing contracts. The exceptions listed relate to requisition approval only.

3.6 Purchase Order Approval Schedule

Total Purchase Amount Delegated Authority level
Less than or equal to $3,000 Principal/Manager (May include purchases Request for Cheque or Procurement Cards)
Greater than $3,000 and less than or equal to $50,000 Buyer
Greater than $50,000 and less than or equal to $250,000 Procurement & Distribution Supervisor
Greater than $250,000 and less than or equal to $1,000,000 Manager of Procurement & Distribution Services
Greater than $1,000,000

Two approvals required:

Manager of Procurement Services and/or Controller, Financial Services and/or Superintendent of Business Services and Treasurer of the Board

3.7 Receipt Approval Authority Schedule

Total Purchase Amount Delegated Authority level
Less than $10,000 The WRDSB utilizes “positive receiving” for smaller value purchase orders. The Requisitioner/Budget Holder is accountable for ensuring all items ordered and charged to their budget have been received in good order. Any exceptions shall be immediately reported to finance-ap@wrdsb.ca.
Greater than or equal to $10,000 Principal/Manager
EXCEPTIONS:
Less than or equal to $100,000 for Construction Projects Facility Services Project Coordinators
Greater than $100,000 and less than or equal to $1,000,000 for Facilities Maintenance & Construction Projects Manager of Capital Projects
Greater than $1,000,000 for Facilities Maintenance & Construction Projects Superintendent of Facility Services

3.8 Payment Approval Authority Schedule

Total Purchase Amount Delegated Authority level
PAYMENTS WITH MATCHING PURCHASE ORDER
Greater than $100,000 Controller, Financial Services
PAYMENTS WITH NO PURCHASE ORDER Invoice Must Include Requisition Level Approval Signature
Less than or equal to $3,000 Accounts Payable Clerk
Greater than $3,000 and less than or equal to $10,000 Accounting Officer
Greater than $10,000 and less than  or equal to $50,000 Manager of Accounting Services
Greater than $50,000 Controller, Financial Services
EXPENSE REIMBURSEMENTS
 Less than or equal to $1,000 Associate Director(s), Superintendents, Controller, Principal, Vice-Principal, Manager, and Supervisor
Greater than $1,000 and less than or equal to $3,000  Superintendent of Business Services & Treasurer of the Board
 Greater than $3,000  Director of Education

Note: All Capital Payments require additional approval by the Budget Officer responsible prior to payment.

4.0 Monthly Report to Board Chairperson of the Board

On a monthly basis, the Superintendent of Business Services & Treasurer of the Board will prepare and submit a report to the Chairperson of the Board listing all disbursements over $50,000.

4008 – Segregation of Duties and Signing Authority