Overall Rating Gold
Overall Score 79.77
Liaison Josh Lasky
Submission Date April 4, 2023

STARS v2.2

George Washington University
OP-11: Sustainable Procurement

Status Score Responsible Party
Complete 2.50 / 3.00 Donna Ginter
Executive Director
Procurement and Travel Services
"---" indicates that no data was submitted for this field

Does the institution have written policies, guidelines, or directives that seek to support sustainable purchasing across multiple commodity categories institution-wide?:

A copy of the policies, guidelines or directives:
The policies, guidelines or directives:
Attached is GW's Procurement Policy for Disadvantaged Businesses for reference.
In addition, GW TERMS AND CONDITIONS ( B.1.f., B.1.g, d.1.D) found here: https://procurement.gwu.edu/sites/g/files/zaxdzs4691/files/downloads/termsandcond.pdf
In addition, GW TERMS AND CONDITIONS ( B.1.f., B.1.g, d.1.D) found here: https://procurement.gwu.edu/sites/g/files/zaxdzs1321/f/downloads/termsandcond.pdf
includes language about supplier expections as it relates to Clean Air Act, Energy Policy and Conservation Act, and tropical hardwood.

Thirdly, GW's Supplier Code of Conduct is also relevant, found here: https://procurement.gwu.edu/gw-supplier-code-conduct . George Washington University is committed to conducting its procurements in an ethical, legal and socially responsible manner. The University expects its suppliers to share this commitment and, therefore, has established this Supplier Code of Conduct. All University suppliers must meet the following minimum requirements in order to do business with the University.

Compliance with Laws, Regulations and Published Standards

All suppliers to GW must comply with all applicable laws, codes or regulations of the countries, states and localities in which they operate. This includes, but is not limited to, laws and regulations relating to environmental, occupational health and safety, and labor practices. In addition, University suppliers must require their suppliers (including temporary labor agencies) to do the same.

Environmental Practices

All suppliers to GW shall comply with all environmental laws and regulations applicable to their operations worldwide. Such compliance shall include, among other things, the following items:

-Obtaining and maintaining environmental permits and timely filing of required reports
-Proper handling and disposition of hazardous materials
-Monitoring, controlling and treating discharges generated from operations

Occupational Health and Safety Practices

All suppliers to GW are expected to provide their employees with a safe and healthy working environment in order to prevent accidents and injury to health arising out of, linked with, or occurring in the course of work or as a result of the operation of the supplier. Suppliers shall, among other things, provide:

-Occupational health and safety training
-A system for injury and illness reporting
-Medical treatment and/or compensation to injured/ill workers arising as a result of working for supplier
-Machine safeguarding and other protective measures to prevent injuries/illnesses to workers
-Clean and safe facilities

Labor Practices

All suppliers to GW are expected to adopt sound labor practices and treat their workers fairly in accordance with local laws and regulations. In addition, suppliers must comply with the following standards:

Freely Chosen Employment - Suppliers shall not use any forced labor, whether in the form of prison labor, indentured labor, bonded labor or otherwise.
No Child Labor - Suppliers shall comply with local minimum working age laws and requirements and not employ child labor.
Minimum Wages - Suppliers shall provide wages for regular and overtime work and benefits that meet or exceed legal requirements.
Working Hours - Suppliers shall not require workers to work more than the maximum hours of daily labor set by local laws.
No Harsh, Inhumane Treatment or Abuse - Suppliers shall treat each employee with dignity and respect. In no event shall Supplier's workers be subject to threats of violence, physical punishment, confinement or other form of physical, sexual, psychological or verbal harassment or abuse.
No Discrimination - Suppliers shall not discriminate in its employment practices on the basis of race, color, religion, sex, age, physical disability, national origin, creed or any other basis prohibited by law.
Freedom of Association - Suppliers shall recognize and respect the rights of its workers to organize in labor unions in accordance with local labor laws and established practices.

Ethical Business Practices

All suppliers to GW are expected to conduct their businesses in accordance with the highest standards of ethical behavior and in accordance with applicable laws and regulations. Suppliers are expected to conform to these requirements in each of the following areas:

Fair Trade Practices - Suppliers shall not engage in collusive bidding, price fixing, price discrimination or other unfair trade practices in violation of antitrust laws.
Bribery, Kickbacks and Fraud - No funds or assets of the supplier shall be paid, loaned or otherwise disbursed as bribes, ""kickbacks"", or other payments designed to influence or compromise the conduct of the University.
Foreign Corrupt Practices Act - While laws and customs vary throughout the world, all suppliers must comply with foreign legal requirements and United States laws that apply to foreign operations, including the Foreign Corrupt Practices Act. The Foreign Corrupt Practices Act generally makes it unlawful to give anything of value to foreign government officials, foreign political parties, party officials, or candidates for public office for the purposes of obtaining or retaining business.

University Policies and Procedures - Suppliers must comply with the University's published policies and procedures, including, but not limited to, the University's Conflict of Interest and Procurement Code of Ethics policies.
Intellectual Property Rights - Suppliers shall respect the intellectual property rights of others, especially the University, its affiliates and business partners. Suppliers shall take appropriate steps to safeguard and maintain confidential and proprietary information of the University and shall use such information only for the purposes specified for use by the University. Suppliers shall observe and respect all University patents, trademarks and copyrights and comply with all requirements as to their use as established by the University. Suppliers shall not transmit confidential or proprietary information of the University via the internet unless such information is encrypted in accordance with minimum standards established by the University.

Export Sanctions and Terrorism Activities

All suppliers to GW must abide by all economic sanctions or trade embargoes that the United States has adopted, whether they apply to foreign countries, political organizations or particular foreign individuals and entities. Suppliers should not directly or indirectly engage in or support any terrorist activity. Neither suppliers nor any of their affiliates, nor any officer or director of the supplier or any of its affiliates, should be included on any lists of terrorists or terrorist organizations compiled by the United States government or any other national or international body, including but not limited to: (i) the U.S. Treasury Department's Specially Designated Nationals List, (ii) the U.S. State Department's Terrorist Exclusion List, (iii) the United Nations List Pursuant to Security Council Resolution 1390 (2002) and Paragraphs 4(B) or Resolution 1267(1999) and 8(C) of Resolution 1333 (2000), and (iv) the European Union List Implementing Article (2)(3) of Regulation (EC) No. 2580/2001 on Specific Restrictive Measures Directed Against Certain Persons and Entities with a View to Combating Terrorism.

Unauthorized Solicitations

All suppliers to GW must comply with all guidelines issued by the University relating to access to University facilities, offices and departments, and employees. No Supplier shall use the University's computer system, including its electronic mail system and internet site, for the purpose of sending unsolicited electronic mail messages to the University community. Suppliers are not permitted to use the University's intramural mail system for unauthorized solicitation to employees. Suppliers must receive prior written authorization from the University's Chief Procurement Office to hold on-campus trade shows, exhibits, or product demonstrations.

Monitoring and Compliance

All suppliers to GW must conduct audits and inspections to insure their compliance with this Supplier Code of Conduct and applicable legal requirements. If a supplier identifies areas of non-compliance, the supplier agrees to notify the Purchasing Services Department as to its plans to remedy any such non-compliance.

The University or its representatives may engage in monitoring activities to confirm Supplier's compliance to this Supplier Code of Conduct, including on-site inspections of facilities, use of questionnaires, review of publicly available information, or other measures necessary to assess supplier's performance. Any University supplier or University employee that becomes aware of violations of this policy is obligated to notify the Purchasing Services Department. Based on the assessment of information made available to the University, The George Washington University reserves the right (in addition to all other legal and contractual rights) to disqualify any potential supplier or terminate any relationship with any current supplier found to be in violation of this Supplier Code of Conduct without liability to the University.

Does the institution employ Life Cycle Cost Analysis (LCCA) when evaluating energy- and water-using products and systems?:

Which of the following best describes the institution’s use of LCCA?:
Institution employs LCCA as a matter of policy and standard practice when evaluating all energy- and water-using products, systems and building components

A brief description of the LCCA policy and/or practices:
GW evaluates all stages of a product's life from the perspective that they are dependent on each other. The procurement office conducts this sort of evaluation when acquiring machinery (copiers, computers and vehicles etc.) and the Facilities/Real Estate division does the same when renovating and constructing new buildings for LEED standards.

For energy efficiency projects (primarily lighting), GW selects the top proposal by using a 7-year NPV -- so that higher-efficiency equipment is given extra consideration.

The procurement Manual, under section 6.2.1 states the following:

6.2.1 Lease-Purchase Decision

""A lease-purchase decision is based on the results of a cost-benefits analysis of the costs to own, costs to lease, and the advantages and disadvantages of any other relevant factors""

""A cost-benefit analysis can take several forms, however consideration of the total costs associated with the life cycle of the equipment, to include asset management and disposal should be made prior to moving forward with a purchase.""

These factors include:
• Length of time the item will be used
• Total of rental payments for the period of time to be used
• Outright purchase price of item
• Transportation and installation price of item
• Maintenance and service costs
• Funds availability and cost of capital
• Obsolescence due to rapid advancement of technology

Additional considerations, depending on the cost, complexity and period of use could include:
• Alternate purchase options
• Use by others after initial purpose has ended
• Continued maintenance by in-house staff if purchased vs. leased

Energy Efficiency Standards

GW shall use energy efficiency standards prescribed by Energy Star for the purchase of energy consuming goods. Energy Star, through its website, provides a qualified list of goods meeting Energy Star’s minimum energy specifications, life cycle costing calculations, life cycle cost formula information, and qualified goods that meet Energy Star’s rating for using less energy and helping to protect the environment. Goods listed on the Energy Star websites’ list of qualified goods will be used as “acceptable brands and models” on response documents. The minimal energy specifications for goods listed on the Energy Star Qualified Goods list should be included in the line item specifications on all response documents for the purchase of major energy consuming goods.

Does the institution have published sustainability criteria to be applied when evaluating chemically intensive products and services?:

A brief description of the published sustainability criteria for chemically intensive products and services:
GW requires its supplier to comply with LEED O+M: Existing Buildings v4 – Green Cleaning Policy Environmental Quality (EQ) prerequisite and Green Cleaning – Product and Materials credit. The supplier must provide annual reporting of the cleaning products used on campus, including the amount of annual expenditure for each product.

At a minimum, the policy must cover green cleaning procedures, materials, and services that are within the building and site management’s control, and include the organization responsible for cleaning the building and building site.

Does the institution have published sustainability criteria to be applied when evaluating consumable office products?:

A brief description of the published sustainability criteria for consumable office products:
GW’s policy specifies a minimum of 30 percent recycled content for paper purchased through our major office supplies provider. Using recycled content helps to avoid the need to harvest trees and disturb forest ecosystems.

Does the institution have published sustainability criteria to be applied when evaluating furniture and furnishings?:

A brief description of the published sustainability criteria for furniture and furnishings:
Per the GW Design Standards, GW uses the LEED certification system as GW's green building guidelines, even when LEED certification is not pursued. This includes but is not limited to guidelines for low VOC adhesives and paints as well as formaldehyde-free and FSC particleboard, agricultural board, plywood and casegoods. The standards can be found here: (https://facilities.gwu.edu/GWDesignStandards or: https://facilities.gwu.edu/sites/g/files/zaxdzs3706/f/downloads/GW%20Design%20Standards%20-%20April%202022.pdf

Does the institution have published sustainability criteria to be applied when evaluating Information technology (IT) and equipment?:

A brief description of the published sustainability criteria for Information Technology (IT) and equipment:
GW has completed an effort to consolidate and optimize data center equipment across campus to ensure energy efficiency and data security.

Does the institution have published sustainability criteria to be applied when evaluating food service providers?:

A brief description of the published sustainability criteria for food service providers:
GW requests all caterers to submit vendor recycling, composting, sustainable practices in writing along with the catering proposal and GW requires caterers to eliminate all single use plastics (meaning no plastic bottles on the bar, no plastic cutlery or serving pieces, no plastic serving, etc) in their proposals as well.

GW also requires its snack vendor that supplies vending machines on campus to use the Partnership For Healthier America (PHA) health and wellness Guiding Principles. The PHA guidelines state that all qualifying health snacks must meet all of the following criteria: under 200 calories, less than 10% of calories from saturated fat, less than 35% of calories or weight from total sugars (unsweetened fruit exempt), and less than 240 mg of sodium. GW's snack vendor is on track to apply PHA's criteria to 50% of GW's vending snacks.

Does the institution have published sustainability criteria to be applied when evaluating garments and linens?:

A brief description of the published sustainability criteria for garments and linens:

Does the institution have published sustainability criteria to be applied when evaluating professional service providers?:

A brief description of the published sustainability criteria for professional service providers:

Does the institution have published sustainability criteria to be applied when evaluating transportation and fuels?:

A brief description of the published sustainability criteria for transportation and fuels:

Website URL where information about the institution’s sustainable procurement program or initiatives is available:
Additional documentation to support the submission:

Data source(s) and notes about the submission:



GW's commitment to LEED silver:

GW paper procurement policy:

GW Parntership for a Healthier America:

GW's compliance with DC foam ban:

Capital Partners Solar Project:

installation of water bottle fillers on campus:


The information presented here is self-reported. While AASHE staff review portions of all STARS reports and institutions are welcome to seek additional forms of review, the data in STARS reports are not verified by AASHE. If you believe any of this information is erroneous or inconsistent with credit criteria, please review the process for inquiring about the information reported by an institution or simply email your inquiry to stars@aashe.org.