DRC Qualified Contractor Code of Conduct

Policy DRCP-QCTRS-001 -- Governing professional standards for all DRC Qualified Contractors

This Code of Conduct establishes the professional standards and obligations for all contractors qualified to participate in projects administered by Deep Retrofit Capital Inc. under the Clean Energy Improvement Program. All DRC Qualified Contractors must read, understand, and agree to this Code as a condition of qualification.

Section 1: Definitions
DRC
Deep Retrofit Capital Inc., the ministerially-designated Program Administrator for the Clean Energy Improvement Program in Alberta.
CEIP
Clean Energy Improvement Program, established under Division 6.1 of the Municipal Government Act (RSA 2000, c.M-26) as amended by Bill 10 (SA 2018, c 6).
Qualified Contractor
A contractor -- whether APEGA-licensed, AAA-licensed, or a General Contractor -- who has met all applicable DRC qualification requirements and has been approved to undertake CEIP-financed improvement projects.
Primary Qualified Contractor
The Qualified Contractor designated as the lead on a specific CEIP project, responsible for overall project delivery, coordination, and warranty.
Project Agreement
The formal agreement between DRC, the property owner, and the Qualified Contractor governing the scope, terms, and conditions of a specific CEIP project.
Eligible Improvement
An energy efficiency, renewable energy, water conservation, or EV infrastructure improvement that meets DRC and regulatory criteria for CEIP financing.
Property Owner
The registered owner(s) of a property participating in a CEIP-financed improvement project.
Municipality
An Alberta municipality that has adopted a CEIP bylaw and entered into an administration agreement with DRC.
ASHRAE
American Society of Heating, Refrigerating, and Air-Conditioning Engineers. ASHRAE standards are referenced in DRC energy audit policy.
Subcontractor
Any contractor engaged by the Primary Qualified Contractor to perform specific portions of work on a CEIP project. Subcontractors must meet applicable licensing and insurance requirements.
Supporting Documentation
All records, certificates, reports, photographs, permits, and other materials required to verify compliance with CEIP project requirements.
Section 2: Background

Deep Retrofit Capital Inc. is designated by the Government of Alberta under Ministerial Order 16/2025 as a Program Administrator for the Clean Energy Improvement Program. DRC is authorized to administer CEIP across all property types -- residential, commercial, farm, and non-designated industrial -- in all Alberta jurisdictions where municipalities have adopted CEIP bylaws.

DRC operates a 100% private-capital model with zero public funds. Revenue is generated through administration fees (maximum 5% of total capital cost) and application fees. This private-capital approach requires rigorous oversight of all project participants to protect investors and property owners.

Qualified Contractors are essential participants in the CEIP ecosystem. They are responsible for the design, installation, and warranty of eligible improvements on participating properties. The quality, integrity, and professionalism of Qualified Contractors directly impacts program outcomes, stakeholder satisfaction, and the viability of DRC's capital model.

This Code of Conduct establishes the minimum standards of behaviour, competence, and accountability expected of every DRC Qualified Contractor.

Section 3: Code of Conduct

3.1 Conduct

All DRC Qualified Contractors shall:

  1. Perform all work in accordance with applicable building codes, professional standards, manufacturer specifications, and DRC project requirements.
  2. Maintain all required professional licences, insurance coverage, and WCB clearance in good standing throughout the period of qualification.
  3. Provide accurate, complete, and truthful information in all communications with DRC, property owners, municipalities, and regulatory bodies.
  4. Complete all projects on time and within the agreed scope and budget, notifying DRC promptly of any material changes or delays.
  5. Ensure all workers and subcontractors on CEIP projects are appropriately licensed, insured, and supervised.
  6. Maintain a safe work environment on all project sites, in compliance with Alberta Occupational Health and Safety legislation.
  7. Treat all property owners, DRC staff, municipal representatives, and other stakeholders with respect and professionalism.
  8. Respond promptly to DRC communications, requests for information, and project-related inquiries within the timelines specified by DRC.
  9. Cooperate fully with DRC quality assurance inspections, audits, and performance reviews.
  10. Maintain complete and accurate project records, including time logs, material receipts, inspection reports, photographs, and warranty documentation.
  11. Protect the confidentiality of all property owner information, financial data, and proprietary DRC program information.
  12. Not engage in any deceptive, misleading, or high-pressure sales practices when interacting with property owners or the public.
  13. Not disparage DRC, other Qualified Contractors, competing programs, or any stakeholder in public or private communications.
  14. Report any known or suspected violations of this Code by other Qualified Contractors to DRC's Contractor Liaison.
  15. Comply with all applicable federal, provincial, and municipal laws and regulations, including the Freedom of Information and Protection of Privacy Act (FOIP).

3.2 Obligations

In addition to the conduct standards above, Qualified Contractors are obligated to:

  1. Submit all required documentation (insurance certificates, WCB clearance, licence renewals) to DRC by the specified deadlines. Failure to provide current documentation may result in suspension of qualification.
  2. Complete all DRC-mandated training, including initial qualification training and any subsequent refresher or update modules.
  3. Participate in DRC's performance monitoring program, including submission of project completion reports, energy performance data, and customer satisfaction surveys.
  4. Provide warranty coverage for all installed improvements as specified in the Project Agreement, and respond to warranty claims within the timelines set by DRC.
  5. Notify DRC within 5 business days of any material change in business status, including changes in ownership, licensing, insurance coverage, legal proceedings, or financial condition that could affect qualification.
  6. Maintain a customer complaint resolution process and cooperate with DRC's Issue Escalation Framework (Section 4) for complaints that cannot be resolved directly.

3.3 Conflict of Interest

Qualified Contractors must avoid any situation that creates or could reasonably be perceived to create a conflict of interest with their obligations under the CEIP program. This includes but is not limited to:

  • Financial relationships with property owners that extend beyond the Project Agreement
  • Ownership interests in properties where they are performing CEIP work
  • Undisclosed relationships with equipment suppliers or subcontractors that could influence project specifications
  • Accepting gifts, incentives, or benefits from any party that could compromise impartial professional judgment

Any actual or potential conflict of interest must be disclosed to DRC in writing before accepting a project assignment. DRC will assess the disclosure and determine whether the contractor may proceed or must recuse themselves from the project.

3.4 FOIP and Confidential Information

Qualified Contractors will have access to personal information of property owners and other stakeholders in the course of their CEIP work. All such information must be handled in accordance with the Freedom of Information and Protection of Privacy Act (FOIP) and DRC's Data Collection, Use, and Privacy Policy (DRCP-PADM-0002).

Specifically, Qualified Contractors must:

  • Collect only the personal information necessary to perform their CEIP work
  • Store personal information securely and limit access to authorized personnel
  • Not disclose personal information to any third party except as required for project delivery or as required by law
  • Return or securely destroy all personal information and project records upon request by DRC or upon termination of qualification
  • Report any known or suspected data breach to DRC within 24 hours of discovery
Section 4: Issue Escalation Framework

4.1 Issue Identification

Issues involving Qualified Contractor conduct or performance may be identified through DRC monitoring, property owner complaints, municipal reports, or self-reporting. Issues are classified as:

Verbal Warning

Minor issues that can be addressed through informal guidance. No formal record unless the issue recurs. Examples: minor documentation delays, minor communication issues.

Written Warning

Documented issues requiring corrective action. A formal record is placed in the contractor's file. Examples: repeated documentation failures, below-target KPI performance, unresolved customer complaints.

Formal Notice

Serious issues that may lead to suspension or removal. Triggers escalation to Tier 2 or above. Examples: code violations, insurance lapses, safety incidents, misleading marketing.

4.2 Escalation Tiers

1 Tier 1: Contractor Liaison

First point of contact for all contractor-related issues. The Liaison works directly with the contractor to resolve issues through guidance, corrective action plans, or additional training. Target resolution: 10 business days.

2 Tier 2: Concerns Officer

Escalated to when Tier 1 resolution fails or the issue is sufficiently serious. The Concerns Officer conducts a formal review, may require additional documentation, and issues a binding determination. Target resolution: 20 business days.

3 Tier 3: Resolution Committee

A panel of DRC board members and independent professionals convened for issues that remain unresolved or involve potential suspension or removal. The Committee reviews all evidence and issues a final DRC determination. Target resolution: 30 business days.

4 Tier 4: Minister

Final escalation point under the regulatory framework. Issues escalated to the Minister of Environment and Protected Areas if all internal resolution processes have been exhausted and the matter involves potential regulatory non-compliance or systemic program concerns.

4.3 Suspension

DRC may suspend a Qualified Contractor's status when:

  • Insurance coverage lapses or falls below minimum requirements
  • WCB clearance expires without renewal
  • Professional licence is suspended by APEGA or AAA (where applicable)
  • A serious safety incident occurs on a CEIP project
  • KPI performance falls below minimum thresholds for two consecutive reporting periods
  • The contractor fails to cooperate with a Tier 2 or Tier 3 review

Suspension takes effect immediately upon written notice. The contractor may not accept new CEIP projects during suspension but must complete any in-progress projects unless DRC directs otherwise. Suspension is lifted when the underlying issue is resolved to DRC's satisfaction.

4.4 Removal

DRC may permanently remove a Qualified Contractor when:

  • The contractor commits fraud, misrepresentation, or criminal conduct related to CEIP work
  • The contractor's professional licence is revoked by APEGA or AAA (where applicable), or the contractor loses required municipal business licensing
  • The contractor fails to remedy the cause of a suspension within 90 days
  • A Tier 3 Resolution Committee determination recommends removal
  • The contractor repeatedly violates this Code of Conduct despite prior warnings and corrective action

Contractors subject to removal have 30 calendar days from the date of the removal notice to submit a written appeal to the Resolution Committee. The appeal must include specific grounds for reconsideration and any new evidence not previously considered. The Committee's determination on appeal is final within DRC's internal processes.