SunPower Human Rights Statement

SunPower Human Rights Statement and California Transparency in Supply Chains Act Disclosures

SunPower Corporation and all of its subsidiaries (collectively "SunPower") are committed to human rights as articulated in the Universal Declaration of Human Rights, the Conventions of the International Labor Organization, the UN Guiding Principles on Business and Human Rights, and the UN Global Compact. SunPower strives to respect these human rights and the national laws of the countries where it operates that encompass and extend these rights. This policy applies to all employees and contingent workers within SunPower.

SunPower's workers are treated with dignity and work in safe and healthy conditions. In addition, SunPower staff are remunerated fairly with living wages and the company observes international norms on working hours. We prohibit the practice of forced labor, child labor, bonded labor, or any exploitative labor practice. SunPower also prohibits recruited employees from paying fees during recruitment to deter the potential for forced labor. SunPower rejects all forms of discrimination and harassment at the workplace, including due to sex (which includes pregnancy, childbirth, breastfeeding, or related medical conditions, the actual sex of the individual, or the gender identity or gender expression), race, color, religion (including religious dress practices and religious grooming practices), sexual orientation, national origin, ancestry, citizenship, marital status, familial status, age, physical disability, mental disability, medical condition, genetic information, protected veteran or military status, or any other characteristic protected by local law or regulation. SunPower is aware of the specific need to protect minority and indigenous person's rights in the countries we operate, as such, SunPower respects the rights of local communities and cultures and attempts to reduce impacts on their ways of life. SunPower also rejects any limitations on free speech, expression, thought, consciousness, religion, and association, including collective bargaining. SunPower actively seeks to protect the rights of its workers by publishing this policy throughout its facilities in local languages, offering human rights trainings, and providing a Compliance and Ethics Helpline.

Human rights violations by our employees are unacceptable and impermissible pursuant to the principles and values embodied in our Code of Business Conduct and Ethics ("Code of Conduct"). If employee's conduct (or failure to act) is inconsistent with the principles and values embraced in SunPower's Code of Conduct, disciplinary action, up to and including termination of employment, may result.

SunPower maintains a zero tolerance policy with respect to corruption, as articulated in our Global Anti-Corruption Compliance Policy. Our protocols to protect against corruption include providing employee training and resources, internal controls to prevent and detect violations of our Global Anti-Corruption Compliance Policy, and carrying out due diligence of third party contractors or suppliers who may interact with government officials.

SunPower holds its suppliers to the same standards as its employees. SunPower does this through its Supplier Code of Conduct, which require suppliers to acknowledge their responsibilities to follow ethical and sustainable business practices, including with respect to human rights. SunPower is committed to the elimination of human trafficking and slavery from its direct supply chain. Accordingly, SunPower requires its direct suppliers to certify that they do not engage in any form of human trafficking and slavery. In order to mitigate the risk of human trafficking and slavery occurring in its supply chain, SunPower has adopted the following measures:

  1. Product Supply Chain Human Trafficking Risk Assessment: SunPower conducts a human trafficking risk assessment of its supply chain on a yearly basis.

  2. Supplier Audits: SunPower retains the right to conduct audits of suppliers to evaluate each supplier's compliance with SunPower's standards regarding human trafficking and slavery in supply chains.

  3. Supplier Certification: SunPower requires direct suppliers to certify that they are not engaged, either directly or indirectly, in human trafficking or slavery and follow corresponding local laws.

  4. Training: SunPower offers training to its employees and guidance to suppliers on human rights that help identify, mitigate, and report on human trafficking and slavery

  5. Accountability & Management Systems: SunPower states in its contracts with suppliers and Supplier Code of Conduct that any violations of SunPower's standards, regarding human trafficking and slavery, may result in the termination of SunPower's business relationship with a supplier.

The above steps also constitute SunPower's efforts to comply with the California Transparency in Supply Chains Act and to take required steps under the United Kingdom's Modern Slavery Act. When applying for U.S. federal government contracts, SunPower will comply with all anti-human trafficking requirements outlined in FAR 52.222-50, and will act in the spirit of that law during all other operations. To comply with SunPower's requirements relating to human trafficking and slavery, a supplier must operate in full compliance with laws, rules, and regulations applicable to human trafficking and slavery in the countries in which it operates, as well as any other applicable laws. Further, SunPower expects its direct suppliers to undertake the necessary measures to ensure that their direct suppliers do not engage in human trafficking and slavery.

As a general rule for approaching human rights due diligence, SunPower will follow efforts recommended by the UN Guiding Principles, which include "assessing actual and potential human rights impacts, integrating and acting upon the findings, tracking responses, and communicating how impacts are addressed." SunPower will use risk-based methods to find locations of high risk for critical issues like human trafficking, and will maintain the ability to perform further due diligence including audits on human rights, labor, ethics and corruption concerns.

SunPower makes all suppliers and business partners aware of its human rights policy and asks them to respect and follow it or a similar policy. SunPower asks it suppliers to continuously improve their observance of human rights, recognizing new interpretations and standards that affect their work.

SunPower has consulted with stakeholders both inside and outside the company to develop this policy. SunPower is especially concerned with views of foreign nationals who work at facilities outside of the United States.

SunPower's Head of Supply Chain is responsible for the execution of this policy and reports to the Board of Directors on progress against the policy. SunPower reviews human trafficking concerns in the context of its supply chain with employees who manage suppliers and form recommendations. SunPower is committed to making all required public disclosures related to human rights practices, including reporting on use of minerals regulated in by the Wall Street Reform and Consumer Protection Act (see Conflict Minerals Policy) and disclosures under the California Transparency in Supply Chains Act.