Moscha Koronias, CPM CBRE Real Estate Manager North Fairfax Drive Suite 720 Arlington, VA Tel Fax.

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1 James Campbell Company Page 1 Goals and Scope of the : James Campbell Company, LLC is committed to providing sustainable, high-performance properties to our tenants. Our policy is to utilize green cleaning practices at all of our buildings. James Campbell Company encourages each property to adopt or enhance environmental policies and practices. This is designed to minimize the environmental impact associated with the cleaning of the building while optimizing the conditions for employee productivity and minimizing human exposure to hazardous chemicals, allergens, irritants, and pollutants. The main intent of this policy is to reduce exposure of building occupants and maintenance personnel to potentially hazardous chemical, biological and particle contaminants, which adversely impact air quality, health, building finishes, building systems, and the environment. Our building engineers and property managers will be trained on the aspects of the Green Cleaning Policy. The property managers will integrate all applicable aspects of this policy into new and existing cleaning contracts. UNICCO, the current cleaning contractor, will be responsible for implementing the procedures and guidelines associated with the green cleaning policy. Western Pest, the pest management service provider, will be responsible for complying with this policy in regards to indoor and outdoor integrated pest management. The building engineers and property managers will be responsible for oversight of contractors to ensure that the required aspects of this policy are implemented in all building cleaning activities. Green Tenant Guidelines have been developed to educate all existing and future tenants on green cleaning activities for the building. This policy will also be used in conjunction with the Sustainable Purchasing Policy and Green Site and Building Exterior Management Policy and Plan. This policy will be implemented by the cleaning contractors in conjunction with the most current version of the UNICCO GreenClean Standard Operating Procedures as an attachment to the contract requirements. Where differences arise between these two policies, the James Campbell Green Cleaning Policy will take precedence. This policy shall be effective immediately and shall continue indefinitely or until amended and/or replaced by a subsequent green cleaning policy. This policy is applicable to the 4100 North Fairfax building, excluding the ground floor retail spaces, which are under separate management. This policy addresses low environmental impact cleaning which includes green cleaning products, and practices, contractor education, low environmental impact cleaning equipment, entryway systems, and integrated pest management. The Green Cleaning program and documentation requirements are the responsibility of UNICCO and building management and are listed in Section 1 Low Environmental Impact Cleaning, Section 2 Low Environmental Impact Cleaning Equipment, Section 3 Entryway Systems, and Section 4 Integrated Pest Management (Indoor and Outdoor). x Moscha Koronias, CPM CBRE Real Estate Manager 4100 North Fairfax Drive Suite 720 Arlington, VA Tel Fax

2 Section 1 Low Environmental Impact Cleaning James Campbell Company Page 2 Requirements All cleaning activities will comply with the criteria listed below. Janitorial staff (UNICCO) will be educated and informed on the following information and criteria. The Green Cleaning Policy requirements and documentation information have been provided to the building cleaning contractor and will be included in any revised or future contracts. The building cleaning contractors are responsible for implementing the policy and procedures into their contracts and cleaning services. Use and follow James Campbell Company Sustainable Purchasing Policy for all cleaning equipment and products and disposable janitorial procedures. All purchases of cleaning equipment, cleaning products, disposable janitorial paper products and trash bags will meet the requirements of the sustainable purchasing policy. Any cleaning measures that this policy does not cover will be performed as described in UNICCO s GreenClean Standard Operating Procedures. (Appendix A) Use of chemical concentrates and appropriate dilution systems. Proper training of cleaning personnel in the hazards, use, maintenance and disposal of cleaning chemicals, dispensing equipment and packaging. Use of hand soaps that do not contain antimicrobial agents (other than as a preservative system), except where required by health codes and other regulations (i.e., food service and health care requirements). Use of entryway systems to reduce particulates and other dirt at building entries per Section 3 of this policy. Use of integrated pest management practices per Section 4 of this policy. Chemical Handling and Storage Protocols established in the UNICCO governing safe handling and storage of cleaning chemicals shall be wholly adopted. QC checks will be used to ensure 100% adoption. All cleaning chemicals are stored in a single storage room located on level P-1 of the building. Safe methods of chemical handling and storage shall be practiced, including placing heavy containers at accessible heights, separating volatile compounds, clearly labeling chemicals that require the use of gloves, and establishing handling protocols to minimize the likelihood of spills. Material safety data sheets shall be filed, in duplicate, in the chemical storage room and the manager s office in clearly labeled binders. The custodial supervisor should ensure that the cleaning staff is educated on procedures to minimize exposures and impacts when managing spills and similar incidents. The J-fill chemical dilution system is located on level P-1 next to the chemical storage room. See Appendix D for information regarding the chemical dilution system used for 4100 North Fairfax. Written procedures for the use of the chemical dilution system shall be located in the chemical dilution area. Maintenance shall be provided per the manufacturer s suggested maintenance schedule.

3 Training James Campbell Company Page 3 Maintenance staff members are responsible for the effective implementation of the green cleaning procedures on a daily basis. Ensuring that the staff is fully informed and educated on products, equipment, and procedures (as well as the goals and priorities driving those product and equipment choices and procedures) is critical to the success of a green cleaning program. All members of the cleaning staff for 4100 North Fairfax are required to participate in an annual 4-hour training session. Topics covered in the annual training include the hazards, use, maintenance, disposal, and recycling of cleaning chemicals, dispensing equipment, and packaging. The training program should take care to help staff understand the environmental and health issues associated with the products and equipment they are using, and their specific responsibilities and expectations as to application and disposal (both of the product and any associated packaging). Refer to UNICCO s GreenClean Standard Operating Procedures page 8 for additional information on training policies. Hand Hygiene All restroom facilities shall include appropriate hand soaps. The building shall use hand soaps that do not contain antimicrobial agents unless required by code. Hand-hygiene notices will be placed in all employee restrooms. Floors 11, 12, 13 utilize waterless hand sanitizing stations to promote hand hygiene. Occupant Feedback This building uses the Angus maintenance management software. UNICCO utilizes this software to identify and address complaints or requests from building occupants. UNICCO staff is available 24/7 to address any emergency complaints; the Angus system is linked directly to mobile devices issued to UNICCO staff members. Staffing Plan JOB TYPE # Staff Hours/day Day Matron 1 8 Day Porter 1 8 Night Cleaner 8 4 Night Supervisor 1 5 Total: 53 Documentation The building manager will be responsible for oversight of building cleaning and pest management contractors to ensure that all required aspects of the are implemented. UNICCO will provide the following information monthly to the building manager: Documentation of green cleaning products and disposable janitorial paper products and trash bags are documented as part of the sustainable purchasing policy. Provide documentation/ specifications on the chemical and cleaner dispensing and dilution equipment used. Provide documentation of all cleaning personnel training in green cleaning practices. Provide documentation identifying the date and activities associated with floor maintenance.

4 James Campbell Company Page 4 Section 2 Low Environmental Impact Cleaning Equipment Requirements Janitorial staff will be educated and informed on the following information and criteria. The janitors will implement a program for the use of janitorial equipment that maximizes effective reduction of building contaminants with minimum environmental impact. Cleaning equipment specifications can also be found in the Sustainable Purchasing Policy. A log will be kept for all powered housekeeping equipment to document the date of equipment purchase and all repair and maintenance activated and include vendor cut sheets for each type of equipment in use in the logbook. Documentation The following documentation is required for UNICCO to provide monthly to the building manager: A record of the janitorial equipment used in the building and a log of the maintenance of each piece of equipment over the performance period. Vendor specifications for each type of equipment in use. A sample maintenance log can be found in Appendix B.

5 Section 3 Entryway Systems James Campbell Company Page 5 Requirements All exterior entrances will be equipped with entryway systems such as grills, grates, or mats. Matting systems can be designed for use both outside and immediately inside entryways. Matting systems should be appropriate to the climate and should have a Class 1 fire retardant rating. High quality mats with a softer, finer texture are appropriate for indoor use to capture smaller, finer particles such as dust and salt from ice-melting compounds, and to remove moisture. The mats must extend a minimum of 10 feet from the building entrance into the interior of the building. Other performance features to look for: Fire Retardant rating that exceeds DOC-FF-1-70, such as National Fire Protection Association 253 Class I and II, which can reduce insurance costs. Electrostatic Propensity levels of less than 2.5 KV, which means that contact should not produce electricity discharges when contacting other people or objects. Constructed with recycled content and rubber backing. High void volume within fibers provides space for trapping dirt below the mat surface and allows water to spread to a larger area for improved drying. Cleaning/maintenance procedures: o Vacuum entryway walk-off mats twice daily, replace mats as directed by supervisor. o Shampoo entryway walk-off mats once per month. o In inclement weather place wet floor signs, remove moisture from floors and replace walk off mats as required to maintain safe and sanitary conditions.

6 James Campbell Company Section 4 Indoor and Outdoor Integrated Pest Management Requirements Page 6 All pest management will comply with the pest management criteria and communication strategy as listed below. The Green Site and Exterior Management Policy and plan integrate this policy by reference. Pest management and cleaning contractors will be educated on the following criteria. Any cleaning products used for pest management purposes must comply with the criteria outlined in the Sustainable Purchasing Policy Section 6: Cleaning Products and Materials. The pest management information has been provided to the building pest management contractor and will be included in any revised or future contracts. The building pest management contractors are responsible for implementing the Section 4 Integrated Pest Management of the and program for their contracts and services. The IPM plan shall govern all components of pest management at the project building and site. The practices identified in this plan shall be wholly adopted and used in 100% of the pest management scenarios at 4100 North Fairfax Drive. Pest Management Criteria Integrated Pest Management (IPM) is an approach to pest control that utilizes regular monitoring and record keeping determining if and when treatments are needed, and employs a combination of strategies and tactics to keep pest numbers low enough to prevent unacceptable damage or annoyance. Biological, cultural, physical, mechanical, educational, and chemical methods are used in site-specific combinations to solve the pest problem. Chemical controls are used only when needed, and in the leasttoxic formulation that is effective against the target pest. Rodent baits shall only be used if they are solid blocks placed in locked, tamper-proof outdoor dispensers. Prior to use of rodent baits, other means of rodent control should be attempted including sealing accesses to the building and mechanical rodent traps. Rodent baits are not considered leasttoxic under any circumstances and will require universal notification if they are used on site. Use Integrated Pest Management (IPM) to control animal and plant pests. o Monitor the pest population and other relevant factors o Conduct routine site inspections (minimum one per month) and maintenance as needed o Accurately identify the pest o Determine the injury and action levels that will trigger treatments o Time treatments to the best advantage o Spot treat the pest (to minimize human and other non-target organism exposure to pesticides and to contain costs) o Select the least-disruptive tactics, including: Sanitation Structural repairs Mechanical and living biological controls Other non-chemical methods o Evaluate the effectiveness of treatments to fine-tune future actions o Educate all people involved with the pest problem

7 James Campbell Company Page 7 Use least-toxic pesticides and herbicides when chemical control is deemed necessary. One method for determining levels of toxicity is the warning label. Those labeled Caution are the least toxic. Danger and Warning signify higher levels of toxicity. When necessary to use an insect growth regulator, use dormant oil. Follow all pesticide and herbicide labels. Pesticides found on the City of San Francisco Tier 3 list are considered least-toxic. Resources available for determining the level of toxicity of pesticides are available on the web: 1. National Pesticide Information Center VA Pesticide Data base City of San Francisco Hazard Screenings of Pesticides List: Emergency Applications In the event of an emergency, pesticides may be applied on the grounds without complying with the earlier stipulations for use of integrated and least-toxic methods. The emergency applications of pesticides are warranted in specific situations that directly affect occupant health and/or safety. Communication Strategy The communication strategy requires that the following information and notice be provided to the building manager so all tenants can be notified as required: a description of the integrated pest management system and a list of all pesticides, including any least toxic pesticide that may be used in the building as part of the integrated pest management system. The contractor will provide the building manager with the product label and material safety data sheet (MSDS) of each pesticide used for the building, the building manager will make the label or MSDS available for review upon request, and the building manager will be available for information and comment. For pesticide applications under normal conditions, the communications strategy requires notification of 100% of building occupants not less than 72 hours before a pesticide, other than a least toxic pesticide, is applied in a building or on surrounding grounds being maintained by the building. For any emergency application of pesticides in the building or on surrounding grounds being maintained by the building notification will be made in advance of the application to the extent possible and a maximum of 24 hours after the application. Notification must include the following: Pesticide product name Active ingredient Product label signal word (e.g., caution, danger ) Time and location of application Contact information for persons seeking more information Western Pest shall utilize the Angus maintenance management software to identify and address occupant complaints or requests in regards to pest problems. Documentation

8 James Campbell Company Page 8 Development, implementation and maintenance of a low environmental impact integrated indoor pest management plan will be used for pest management. Documentation of the strategies and procedures performed and products used to control pests will be provided monthly by the pest management contractors to the building manager. See Appendix C for a sample Pesticide application log. Recordkeeping is required to demonstrate ongoing compliance with the IPM plan. All inspections and applications of pesticides (include least-toxic options) shall be logged. The log shall include the following information: Universal Notification to Occupants (N/A for inspections) o Date o Time o Method Pesticide Application Date and Time (N/A for inspections) Responsible Party Location Target Pest (N/A for inspections) Pesticide Trade Name (N/A for inspections) Pesticide Active Ingredient (N/A for inspections) EPA Registration Number (N/A for inspections) Least-toxic status (Y/N) (N/A for inspections) The party(s) responsible shall periodically evaluate the success of the plan. This evaluation may include producing and providing a report on an annual basis to senior management. Whenever possible, the annual reports shall include an evaluation of the performance, safety, cost and environmental/public health benefits achieved as a result of its implementation. Definitions Integrated Pest Management (IPM): is the coordinated use of pest and environmental information and pest control methods to prevent unacceptable levels of pest damage by the most economical means, and with the least possible hazard to people, property and the environment. Least toxic pesticides: Least-toxic pesticides are defined by the City of San Francisco s Hazard Tier 3 criteria (least hazardous): Least-toxic pesticide status also applies to any pesticide product, other than rodent bait, that is applied in a self-contained, enclosed bait station placed in an inaccessible location, or applied in a gel that is neither visible nor accessible.

9 Quality Assurance James Campbell Company Page 9 The building manager shall periodically evaluate the success of the green cleaning purchases and operations by reviewing the purchasing records and tenant work orders on a monthly basis. The Property Manager and/or vendor shall document relevant site activities on an ongoing basis. Building personnel and/or vendor responsible for green cleaning shall report activities to the Property Manager using a designated tracking sheet. Vendor is responsible for demonstrating compliance with particular sustainability criteria. Whenever possible, vendor should demonstrate the environmental and public health benefits of purchasing each sustainable good. The property manager shall occasionally evaluate successes and challenges related to the Plan s ongoing implementation. The Property Manager shall review all relevant practices and products prior to contract renewals to identify opportunities for Plan improvement.

10 James Campbell Company Page 10 Appendix A: UNICCO Green Clean Standard Operating Procedures Attached as a separate document

11 Appendix B: Sample Cleaning Equipment Maintenance Log James Campbell Company Page 11 Janitorial Equipment: Repair and Maintenance Log DATE OF ACQUISITION: STORAGE LOCATION: G-1 Equipment Type Vacuum Cleaners 2012 Brand Name Model No. Serial No. ProTeam 1500XP Daily Maintenance Plan 1. Check Bag for fullness. Replace or empty bag as needed. 2. Inspect bag for tears or holes. Replace if damage. 3. Check power cord for damage. Replace is damaged. Periodic Maintenance Plan Performed by: UGL Services 1. Inspect intake chamber for any accumulated debris, Clean if necessary. 2. Tip Machine back and inspect brush are for obstructing debris, string, etc. Clean if necessary. 3. Assess filters and clean if necessary. Service Date Serviced By Type of Maintenance or Repair Description of Maintenance Performed /Repair Completed In/Out of Service Dates 1/3/2012 UGL Services Daily Maintenance See procedure listed above. Maintenance performed on site. 1/4/2012 UGL Services Daily Maintenance See procedure listed above. Maintenance performed on site. 1/5/2012 UGL Services Daily Maintenance See procedure listed above. Maintenance performed on site. 1/6/2012 UGL Services Daily Maintenance See procedure listed above. Maintenance performed on site. 1/9/2012 UGL Services Daily Maintenance See procedure listed above. Maintenance performed on site. 1/10/2012 UGL Services Daily Maintenance See procedure listed above. Maintenance performed on site. 1/11/2012 UGL Services Daily Maintenance See procedure listed above. Maintenance performed on site. 1/12/2012 UGL Services Daily Maintenance See procedure listed above. Maintenance performed on site. 1/13/2012 UGL Services Daily Maintenance See procedure listed above. Maintenance performed on site. 1/17/2012 UGL Services Periodic Maintenance See procedure listed above. Maintenance performed on site. 1/18/2012 UGL Services Daily Maintenance See procedure listed above. Maintenance performed on site. 1/19/2012 UGL Services Daily Maintenance See procedure listed above. Maintenance performed on site. 1/20/2012 UGL Services Daily Maintenance See procedure listed above. Maintenance performed on site. 1/23/2012 UGL Services Daily Maintenance See procedure listed above. Maintenance performed on site. 1/24/2012 UGL Services Daily Maintenance See procedure listed above. Maintenance performed on site. 1/25/2012 UGL Services Daily Maintenance See procedure listed above. Maintenance performed on site. 1/26/2012 UGL Services Daily Maintenance See procedure listed above. Maintenance performed on site. 1/27/2012 UGL Services Daily Maintenance See procedure listed above. Maintenance performed on site. 1/30/2012 UGL Services Daily Maintenance See procedure listed above. Maintenance performed on site. 1/31/2012 UGL Services Daily Maintenance See procedure listed above. Maintenance performed on site.

12 Appendix C: Sample Integrated Pest Management Log James Campbell Company Page 12 Notification to Occupants: Date, Time, Method Date, Time Service Provided Observations/ Comments Responsible Party Location Target Pest Pesticide Trade Name, Active Ingredient EPA Registration Number Least Toxic? N/A AM Pesticide Application N/A Jenny Carney , 8:30 AM, Notification Signs Posted AM Pesticide Application N/A Keith Amann N/A AM Visual Inspection No Problems Found Joe Schmoe Southwest Entrance Wall void, Rm 208 All floors and outside Ants Carpenter Ants Orange Guard, AA d-limonene 5.8% Tim-bor Industrial, disodium ZC octaborate 98% N/A N/A N/A N/A Y N

13 Appendix D: J-Fill Chemical Dilution System James Campbell Company Page 13

14 James Campbell Company Page 14

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