The GW Medical Faculty Associates (MFA) is committed to conducting its procurements in an ethical, legal and socially responsible manner. The MFA expects its suppliers to share this commitment and, therefore, has established this Supplier Code of Conduct. All MFA suppliers must meet the following minimum requirements in order to do business with the MFA.
Compliance with Laws, Regulations and Published Standards
All suppliers to the GW Medical Faculty Associates 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, MFA suppliers must require their suppliers (including temporary labor agencies) to do the same.
Supplier will conduct business using environmentally, socially, and economically sustainable products and services; defined as products and services with a lesser or reduced effect on human health and the environment, and which generate benefits to the MFA as well as to society and the economy, while remaining within the carrying capacity of the environment. Supplier acknowledges that failure to comply with any of the sustainability standards and requirements within an agreement grants the MFA the right to terminate the Agreement without damage, penalty, cost or further obligation.
A. Sustainability Marketing Standards. Supplier sustainability related claims, where applicable, must meet recognized industry certifications and standards and/or meet the standards of Federal Trade Commission’s (FTC) Green Guides.
B. Electronic Transfer of Supplier Information. Suppliers, when interacting with the MFA, shall be prohibited from providing hard copies of presentations, marketing material, or other informational materials. Suppliers will be required to present all information in electronic format that is easily transferable to MFA staff. Materials may be provided in hard copy or physical format if specifically required or requested by a MFA representative.
C. Packaging Requirements. The MFA requests that all packaging meet at least one of the criteria listed below:
a. Uses bulk packaging;
b. Uses reusable packaging (e.g. totes reused by delivery service for next delivery);
c. Uses innovative packaging that reduces the weight of packaging, reduces packaging waste, or utilizes packaging that is a component of the product;
d. Maximizes recycled content and/or meets or exceeds the minimum post-consumer content level for packaging in the U.S. Environmental Protection Agency Procurement Guidelines;
e. Uses locally recyclable or certified compostable material.
All suppliers to the MFA 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 the MFA 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 the supplier
- Machine safeguarding and other protective measures to prevent injuries/illnesses to workers
- Clean and safe facilities
All suppliers to the MFA 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 forms 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 the MFA 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 MFA.
- Foreign Corrupt Practices Act - While laws and customs vary throughout the world, all suppliers must comply with foreign legal requirements and the 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.
- MFA Policies and Procedures - Suppliers must comply with the MFA's published policies and procedures, including, but not limited to, the MFA's Conflict of Interest and Procurement Code of Ethics policies.
- Intellectual Property Rights - Suppliers shall respect the intellectual property rights of others, especially those of the MFA, its affiliates, and business partners. Suppliers shall take appropriate steps to safeguard and maintain confidential and proprietary information of the MFA and shall use such information only for the purposes specified for use by the MFA. Suppliers shall observe and respect all MFA patents, trademarks and copyrights and comply with all requirements as to their use as established by the MFA. Suppliers shall not transmit confidential or proprietary information of the MFA via the internet unless such information is encrypted in accordance with minimum standards established by the MFA.
Export Sanctions and Terrorism Activities
All suppliers to the MFA 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.
All suppliers to the MFA must comply with all guidelines issued by the MFA relating to access to MFA facilities, offices and departments, and employees. No Supplier shall use the MFA's computer system, including its electronic mail system and internet site, for the purpose of sending unsolicited electronic mail messages to the MFA community. Suppliers are not permitted to use the MFA's intramural mail system for unauthorized solicitation to employees. Suppliers must receive prior written authorization from the MFA's AVP, Procure-to-Pay, to hold on-campus trade shows, exhibits, or product demonstrations.
Monitoring and Compliance
All suppliers to the MFA must conduct audits and inspections to ensure 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 Procure-to-Pay Office as to its plans to remedy any such non-compliance.
The MFA or its representatives may engage in monitoring activities to confirm the 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 MFA supplier or MFA employee that becomes aware of violations of this Code of Contact is obligated to notify the Procure-to-Pay Office. Based on the assessment of information made available to the MFA, the MFA 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 MFA.