ESG Enforcement Tracker

Key facts:

On 7 July 2025, Stantec and its wholly owned subsidiary, Cardno, entered into a settlement agreement with the DOJ. The settlement agreement relates to allegations that Stantec and Cardno violated the False Claims Act by submitting or causing the submission of applications for specific grants to the Environmental Protection Agency (EPA) from December 2014 to December 2022, which falsely certified compliance with federal procurement regulation 2 C.F.R. section 200.319.

The EPA’s Brownfields Grant Program provides grants and technical assistance to communities, states, and others to assess, safely clean up and sustainably reuse contaminated properties, for example, shuttered gas stations. The Brownfields assessment grants (the assessment grants), which are the subject of the settlement agreement, provide funding to conduct inventories, planning, environmental assessments etc. to revitalise real property that contains a hazardous substance. Recipients of assessment grants are required to confirm that they have complied with competitive procurement standards required by federal regulation, specifically 2 C.F.R. section 200.319, which states that contractors that develop or draft specifications must be excluded from competing from those procurements to eliminate unfair competition.

The DOJ alleges that Stantec and Cardno assisted applicants for the assessment grants by drafting specifications and statements of work that the applicants would issue publicly to solicit proposals for assistance in applying for and implementing the assessment grants. However, allegedly in contravention of 2 C.F.R. section 200.319, both companies submitted proposals to 75 applicants in response to the solicitations and subsequently won contract awards. They prepared assessment grant applications on behalf of these applicants, which contained express representations of compliance with 2 C.F.R. section 200.319. The DOJ alleges that the EPA relied on the truth and accuracy of the information when making grant award decisions and all 75 applicants received the assessment grants.

Stantec and Cardno deny the allegations. To avoid protracted litigation, they entered into the settlement agreement with the DOJ, pursuant to which they agreed to pay US$4 million.