Powering a
Circular Economy:
Sustainable
Manufacturing& Recycling2023

Table ofcontents

Introduction

3

Powering a circular economy

4

Circular economy practices

4

Sustainable manufacturing and recycling

5

Sustainable supply chain

5

Sustainable manufacturing

7

Sustainable product8

Sustainable packaging

9

Maxeon’s recycling process

10

Maxeon takeback policy

11

Maxeon’s partner requirements

12

Global recycling regulations

13

Regulatory & non-regulatory frameworks

13

Information and resources

17

Introduction
Maxeon Solar Technologies, Ltd. (“Maxeon”) is committed to the protection of
the environment through a circular economy approach. This includes responsible
product life-cycle management, from materials sourcing through manufacturing,
all the way to recycling.
Some of our successes are being certified by: (i) Declare for the transparency ofthe materials in our products; (ii) NSF for having a landfill-free facility; (iii) LEED forfive Gold or Platinum rated buildings; (iv) the Cradle to Cradle Products Innovation
Institute as a Silver-rated company under its Cradle to Cradle criteria, the highest
in the solar industry; and (v) ISO14001:2005 Environmental Management Systems(EMS), which is the international standard that provides
a framework for organizations to improve environmental performance.
As a validation of our efforts to date, we were recently named one of the top 100
most sustainable companies in the world (out of nearly 7000 evaluated)by Corporate Knights.
This document is designed to share key learnings on our sustainability journey withrespect to the circular economy. Our Powering a Circular Economy program is being
continually enhanced to achieve better performance over time for the benefit ofour people and planet.
Please contact us with any questions or comments on this document at
esg@maxeon.com.

3© 2023 MAXEON SOLAR TECHNOLOGIESPOWERING A CIRCULAR ECONOMY

Circular economy practices
Panels as clean as the energy they produce

Circular economy is a concept that closely aligns with Maxeon’s commitment to the United Nations’Sustainable Development Goal (UN SDG) 12: ‘Responsible Consumption and Production.’
This relates to the efficient use and management of natural resources whilst ensuring waste
is reduced and repurposed to result in a closed-loop system. This “cradle to cradle” approachis outlined below and has been certified by many respected international bodies.

Materials sourcing

Production

Product use

Product re-use•

Screen suppliers for carbon footprint andother environmental metrics••

Our panels make a significant contribution to
LEED® certification for commercial buildings•

We take back panels that are under warranty
through our Takeback Policy for recycling•

Public disclosure of all panel materials
with Declare label*

•

•

•

Lead-free and RoHS and REACH-SVHC
compliant, meeting strict standards set forover 190 harmful chemicals in the EU

Our 40-year product warranty ensuressystems will be producing clean energy for
decades to comeWe support our customers in their recycling
efforts by working with local recycling experts
in the countries where we operate

•

•

•

Supplier adherence to Maxeon policies toreduce the consumption of natural resources
and use of hazardous substances

Our high panel efficiency can reduce thevolume of materials needed for cables,
connectors and balance of systems

We take a collaborative approach withrecyclers, encouraging them to develop
innovative ways to process materials for asecondary use*Our Maxeon Line panels are Declare Label certified

4

Industry’s first and only Zero-Waste-ToLandfill certified manufacturing facility• <1% of material from our facility in Mexico
is sent to a landfill and <10% of material issent to a waste-to-energy facility•

Components produced in LEED Gold-certified
factories® in Malaysia, Philippines & Mexico•

Cradle to Cradle Certified Silver,
demonstrating high standards in material
health, water stewardship and social fairness•

Zero-tolerance policy for any violationsof local and international human and laborrights standards among our suppliers andmanufacturing partners.
© 2023 MAXEON SOLAR TECHNOLOGIESSUSTAINABLE MANUFACTURING AND RECYCLING

Sustainablesupply chain

Occupational
healthand safety

Clean from the start
At the beginning of the process of bringing a Maxeon product into the world,
we endeavor to work with suppliers that are not only best in class in quality andcompetitive in price, but also suppliers that match our values.
We have incorporated ESG factors into the selection process for suppliers of our
products. Factors we consider include all aspects of ESG:
• E - Environmental factors such as carbon footprint and packaging

Fair labourand humanrightsPowering
positivechangeCommunity
investment

Employeeengagement

Employees, suppliersand community• S - Commitment to international fair labor and human rights standards• G - Adherence to Maxeon standards on anti-corruption andother governance measures
We ensure our suppliers’ ongoing commitment through annual certification of our
Supplier Sustainability Guidelines and by requiring our suppliers to attend trainings
on our Code of Conduct.

Diversity
andinclusion

Learning
anddevelopment

Due to the complex and multi-layered nature of global supply chains, we require
suppliers to commit not only to their practices but to account for their supply chainsas well, including the use of raw materials.
5© 2023 MAXEON SOLAR TECHNOLOGIESSUSTAINABLE MANUFACTURING AND RECYCLING

Sustainable supply chain
Trailblazing new approaches

As part of our commitment to being an industry leader, in 2022
we initiated a pilot supplier sustainability monitoring program with
Singapore-based, ESG fintech Hashstacs Pte Ltd (STACS) via its
ESGpedia platform, which powers the ESG registry of the Monetary
Authority of Singapore (MAS) Project Greenprint.
Maxeon and STACS embarked on the project to leverage holistic ESG
data and digital tools on ESGpedia for monitoring the sustainability
performance of suppliers in Maxeon’s end-to-end supply chain.
As a registry with a reliable record of sustainability certificationsand verified ESG data across various sectors, ESGpedia provides
Maxeon a common point of access for holistic ESG data. Thisfacilitates better tracking and analysis of suppliers’ sustainability
commitments, impact measurement, while alleviating concerns ofgreenwashing.
The ESGpedia platform also enables Maxeon to select suppliers basedon their emissions and provide greater transparency of our carbon
footprint to our stakeholders.

6© 2023 MAXEON SOLAR TECHNOLOGIESSUSTAINABLE DESIGN & RECYCLING

Sustainable
manufacturing

Putting our values in our processes
The areas of focus in Maxeon’s sustainable manufacturing process include:

Compliance obligations
and due diligence

Sustainable facilities

Stakeholder engagement

Ensure compliance to all applicable regulatory
and statutory requirements.

Components produced in LEED Gold factories
in Malaysia, Philippines & Mexico, embarking on
decarbonization by procuring renewable energy.

Regulatory and local government units,
nearby communities, external providers andother external organizations.

Environmental footprint
and impact

Environmental monitoringand measurement

Social impact

Resource consumption reduction,e.g., Materials/ Chemicals, Energy, Water,
Waste Reduction, Green House Gas Emission
Reduction, Wastewater Discharge Reduction,
Material Recovery and Reuse throughout the
product lifecycle.

Auto Detection Systems to eliminate or reducereleases and exposure to toxic substances.

Efficiency and waste reduction

Operations run as designed to ensure minimal
environmental degradation. Installation of
Abatement Systems plus backup to ensure alldischarge and emissions are treated prior torelease to environment.

Equipment design for green and efficient
production, use of materials that areenvironmentally responsible, elimination ofnumerous process steps to reduce material usage
and waste, automation to eliminate manual
handling and exposure to hazardous materials.
7

Human rights, labor management, health &safety etc.

EconomyOperational andabatement controls

Respond to customer needs and reach newcustomers; increase competitive edge;
strengthen brand and reputation; andcontinuous innovation.

© 2023 MAXEON SOLAR TECHNOLOGIESSUSTAINABLE DESIGN & RECYCLING

Sustainable productPanels that stand the test of time
Solar panels with longer lifetimes reducedemand for new materials. The Sunpower
Maxeon panel line is backed by the solar
industry’s best-in-class warranty of 40 years,
the longest lifetime in the industry.

Additionally, longer operating life meansthat significantly more clean energy is
generated by each panel, greatly improving
the environmental footprint of thetechnology.

The US National Renewable Energy
Laboratory (NREL) has evaluated the tradeoffs between extending PV module lifetimes
or ramping up closed-loop recycling for solar
panels with shorter lifetimes and publishedits findings in PLOS One. The results showthat modules with longer lifetimes reduce newmaterial demand through lower deployment,
resulting in less waste. It was concluded
that offsetting new material demand can beaccomplished in ways other than recycling,including high-yield, high-efficiency, reliable
systems (thereby reducing replacement andtotal deployment needs), remanufacturing ofcomponents, and circular material sourcing.

The new SunPower Maxeon 40-Year
Warranty is based on external field studies
from more than 33 million Interdigitated
Back Contact (IBC) panels deployedworldwide, comprehensive accelerated life
testing by Maxeon and third parties, and aphysics-based model which Maxeon uses
to determine the expected performance
impact over time from major degradationand failure modes. The result is an
unprecedented 88.3 percent warranted
power level at the end of 40 years, meaning
Maxeon IBC panels deliver up to 9.5% more
power after 40 years than standard solar
panels deliver after 25 years.

8

Collectively, these results give Maxeon andour customers confidence that the SunPower
Maxeon module technology can support a
40-year warranted life, and that continued
operation beyond this period is certainly
feasible.
Maxeon’s high efficiency, high yield andindustry’s longest warranty of 40 years
could reduce new material demand, resulting
in less waste, lower carbon emissions andenvironmental impact.

© 2023 MAXEON SOLAR TECHNOLOGIESSUSTAINABLE DESIGN & RECYCLING

Sustainable packaging
Lean and green

Maxeon’s policy is to use reusable package
designs over expendable or recyclable ones,
provided other costs are equivalent and safety
and product protection are not compromised.
The design of a reusable container system
is a joint effort between Maxeon, suppliersand contractors. The involvement of eachparty is necessary to fully understand andaccount for the logistics affecting operations
at all locations. Contractors need to clearly
understand the process to collect, store,bundle and return packaging. Where areturnable packaging solution is in place,consideration is given to a collapsible designfor optimization of Maxeon’s return program.
If recycling is unavoidable, packaging
materials are marked with the applicable
recycling code. The code with chasing arrows
and material abbreviation shall be legible tothe end user/customer.
9

The overall result is as little packaging as
possible.
Some of the packaging regulations andstandards we follow around the world include:

Standards• EN 13427:2004 Requirements for the use ofEuropean Standards in the field of
packaging and packaging waste• Directive 94/62/EC on Packaging and 				Packaging Waste, and its amendments• EN 13428:2004 Requirements specific tomanufacturing and composition: Prevention
by source reduction• Directive EC/1907-2006 Registration, 			
Evaluation, Authorization and Restrictionof Chemicals (REACH)• EN 13430 Requirements for packaging
recoverable by material recycling• U.S. Labeling Guidelines: Federal Trade
Commission “Environmental Marketing
Guides” (Similar in UK and Canada)• Life Cycle Assessment General Principles
Standard: ISO 14040:1997• Australian Packaging Covenant:
https://apco.org.au/• AS/NZS ISO 14021:2000 Australia &New Zealand Standard, Environmental labelsand declaration: Self declaredenvironmental claims© 2023 MAXEON SOLAR TECHNOLOGIESSUSTAINABLE DESIGN & RECYCLING

Maxeon’s
recycling process

A fresh start for our retired panels

Log all serial numbersof the modules to be recycled

Modules are picked up
at Maxeon (or regional
Maxon locations)Maxeon has implemented a recycling process for PV modules returned under warranty toensure reliability and safety procedures are adhered to during the process.
The serial numbers of the modules to be recycled are first recorded by Maxeon, then themodules are picked up at Maxeon (or regional Maxeon location) by the recycling provider.
The recyclers log module serial numbers at their facility, and post to our page on theirwebsite. Maxeon matches their list with the initial list and once matched, Maxeon gives the
go-ahead to begin the mechanical recycling process. The modules are then disassembled
and processed as follows:• Aluminum framing sent to metals recycler,

Recyclers log module serial
numbers at their facility andpost to their website

Maxeon to match the serial
numbers of the list of modules
to be recycled• J-Box/plastics ground and sent to plastics recycler,• Wire stripped to components, and copper, rubber sent to appropriate recycler, and• Remaining module is then broken and ground into small pieces and sent toreclaim processor, where it is melted down and the glass, silicon, etc.,
separated and recycled.
10

Modules are disassembled
and processed before
sending to recyclers© 2023 MAXEON SOLAR TECHNOLOGIESSUSTAINABLE DESIGN & RECYCLING

Maxeon’s takeback policy
Taking accountability for what we produce
Maxeon Solar Technologies is committed to being a responsible producer and provides appropriate reuse
and recycling options for our products. In compliance with all local and national regulations, our Takeback
Policy takes a collaborative approach with recyclers, encouraging them to develop innovative ways toprocess materials for a secondary use. In each case, we work with local recycling experts in the countries
where we operate. Our agreements with government-authorised partners are designed to provide the mostefficient return, separation and reclamation possible.

Australia

EuropeAlthough there is no local legal obligation, we work with local
partners to collect and recycle the PV panels. Reclaimed cells
are tested and integrated back into the PV industry wherever
possible. Otherwise, they are recycled.

Through Maxeon’s membership in the Waste from Electrical andElectronic Equipment (WEEE) Directive, Maxeon pays a provision
for every panel at the time of sale. This ensures resources areavailable for our partners to organise the collection and recyclingof all Maxeon warranted panels.

Japan
In accordance with the Waste Management Law,
our solar panels are recycled by two regionally authorised
partners, Hamada and Kinki Denden
Yusou Co, who target the separation and recyclingof as many elements as possible.

United States
SunPower co-led the first US-based industry-wide recycling
program with the Solar Energy Industries Association,and requires all recycling vendors to be either R2/RIOS or
e-Stewards certified.
11

France – SOREN
Italy – ERP
Germany – PV Cycle Deutschland
Netherlands – Stichting OPEN
Spain – PV Cycle Aisbl / ECOASIMILEC Foundation
UK – PV Cycle UK
In our smaller EU markets and rest of the world, WEEE
compliance is managed through our partner and distributor
networks. By joining the EU PV Alliance, we are also actively
improving our supply chain to be more sustainable and resilient.
© 2023 MAXEON SOLAR TECHNOLOGIESSUSTAINABLE
RECYCLING
CERTIFICATIONSDESIGN & RECYCLING

Recycling partner requirements
Holding our partners
to the highest standards
Our module recyclers are required to have either the R2/
RIOS or e-Stewards certification. These certifications
confirm that the company has appropriate environmental,
health and safety (EH&S) management systems, a hierarchy
for responsible waste management strategies, and complies
with all applicable legal requirements related to data
security and import and export of waste. In addition tothese certifications, all recyclers must provide relevant
OHSAS and ISO certifications where relevant.

12© 2023 MAXEON SOLAR TECHNOLOGIESGLOBAL RECYCLING REGULATIONSRegulatory &non-regulatory frameworks (cont.)
The amount of solar waste is set to rise rapidly after 2030. Therefore, there are increasingly
more guidelines and regulations being implemented globally as countries prepare for the influx.
Maxeon takes into consideration these global regulatory frameworks when implementing ourrecycling program. These include but are not limited to the jurisdictions described herein.
European Union (EU) Waste Electrical andElectronic Equipment Directive (WEEE Directive)

United Kingdom’s regulatory andnon-regulatory frameworks

EU has set up one of the main regulatory frameworks based on WEEE
directives to address electrical and electronic waste. The objective of thisframework is to effectively address the electrical and electronic waste
generation in the 28 EU member states and define certain responsibilities
among different stakeholders. According to the WEEE directives, allelectrical or electronic product producers are legally accountable forproper waste management of products sold within the EU, no matter
where their manufacturing facilities are located. The WEEE directive has
detailed guidelines that includes collection, recovery, and recycling, alongwith environment and public health safety.

The WEEE Regulations 2013 came into force in the UK on January 1, 2014.
PV module producers are required to share certain data, such as the numberof PV modules produced or imported, and their delivery network channels,
and should also maintain a registered product conformity plan.

According to the latest WEEE directive, PV producers have primary liability
for the costs of collection, handling and treatment of solar panels waste.
13

Producers have obligations both in terms of the waste from electronic orelectrical equipment (WEEE) they sell and in terms of financing the collection,
treatment, recovery and environmentally sound disposal of WEEE. Those
producers who sell direct to households in the UK (e.g. retailers, internet
sellers and other distance sellers) have additional obligations as a distributorof household WEEE.

© 2023 MAXEON SOLAR TECHNOLOGIESGLOBAL RECYCLING REGULATIONSRegulatory &non-regulatory frameworks (cont.)
United States of America’s regulatory and non-regulatory framework
In addition to generally applicable laws governing waste disposal (i.e., Resource Conservation andRecovery Act (RCRA)), some states have started to develop tailored regulations for the collection,
handling and use of end-of-life PV modules.
The solar waste regulations of the top five U.S. solar states include1:• California: PV modules are considered “universal waste,” a lesser classification of hazardous
waste that eases some transport issues and costs for recyclers to facilitate financiallysustainable recycling operations.
• North Carolina: Regulation N.C. H329, passed in 2019 that addresses solar panel stewardship• Arizona, Florida and Texas: Common waste regulation
The RCRA is the public law that creates the framework for the proper management of hazardousand non-hazardous solid wastes. Regulations under the RCRA must be followed to ensure that
solar panel waste is safely recycled or disposed of.

Referenced from PV Magazine: https://pv-magazine-usa.com/2020/12/03/solar-panel-recycling-in-the-us-a-looming-issue-that-could-harm-growth-and-reputation1

14© 2023 MAXEON SOLAR TECHNOLOGIESGLOBAL RECYCLING REGULATIONSRegulatory &non-regulatory frameworks (cont.)
Singapore’s Extended Producer Responsibility (EPR)
system for e-waste management system
The Singapore National Environment Agency (NEA) has
introduced a regulated e-waste management system thatwill ensure the proper collection and handling of e-waste
and the extraction of valuable resources from e-waste.
The regulated e-waste management system will also
safeguard the environment and our health.
The regulated e-waste management system is based on
the Extended Producer Responsibility (EPR) approach,where producers bear the responsibility for the collection
and treatment of their products when they reach end-of-life.
This EPR system is implemented through the Resource
Sustainability Act (RSA), administered by the NEA. In addition,
ALBA E-waste Smart Recycling Pte Ltd has been appointed as the
Producer Responsibility Scheme (PRS) Operator for a period offive years, from 1 July 2021 to 30 June 2026, to collect regulated
consumer electrical and electronic waste across Singapore forproper treatment and recycling on behalf of producers.

15

Extended Producer Responsibility (EPR) for e-waste by 2021
Producers of EEE)

Producer Responsibility Scheme (PRS) Operator

Consumer e-Waste

Electrical & Electronic
Equipment (EEE)• ALBA e-waste Smart Recycling is NEA’s appointed PRS Operator• ALBA collects consumer e-waste and sends it for proper treatment.
• ALBA is financed by producers of EEE. Small produceres are
exempted from this requirement.
• NEA tracks ALBA’s performance in meeting collection targets.
• ALBA drives e-waste public education programmes and provides
avenues for consumers to drop off e-waste, such as:
Collection Drives, Doorstep Collection, E-waste bins

e.g. mobile phones,
laptops & large
household appliances

Retailers• Retailers provide 1-for-1 take-back of the consumer’s old regulated
consumer product at no cost, upon delivery of a new product.
• Retailers of EEE with floor area 300m2 and above provide in-store
collection points (e-waste bins or over-the-counter) for small
consumer e-wate (e.g. mobile phones, laptops light bulbs and batteries)• Retailers hand the collected e-waste to the PRS Operator for recycling:
Retailer 1-for-1 take-back, E-waste bins, Over-the-counter collection

Consumers& Businesses

Non-Consumer
e-Wastee.g. solar panels &data servers

e-WasteRecyclers

Producers of Non-consumer EEE• All producers provide take-back services of their end-of-life products totheir clients upon request, at no additional cost to the client.
Producer take-back© 2023 MAXEON SOLAR TECHNOLOGIESGLOBAL RECYCLING REGULATIONSRegulatory &non-regulatory frameworks (cont.)
Australia’s national waste policy (2018)
Most preferable

The 2018 National Waste Policy provides a framework forcollective action by businesses, governments, communities andindividuals until 2030.

• Avoid waste;• Improve resource recovery;• Increase use of recycled material and build demand and 			markets for recycled products;• Better manage material flows to benefit human health,the environment and the economy; and• Improve information to support innovation, guideinvestment and enable informed consumer decisions.

Reduce waste

The waste hierarchy

The policy identifies five overarching principles underpinningwaste management in a circular economy. These include:

Avoid waste

Reuse waste

Recycle waste

Recover (including energy)

Treat (including hazardous waste)

Dispose of waste

Less preferable
16© 2023 MAXEON SOLAR TECHNOLOGIESINFORMATION AND RESOURCES

Resources available
For more information on Maxeon Environmental,
Social and Governance (ESG):
Corporate ESG information: corp.maxeon.com/esg
Sustainability Report 2021: corp.maxeon.com/esg/sustainability-reports/report-2021
Latest sustainability updates: corp.maxeon.com/blog

17© 2023 MAXEON SOLAR TECHNOLOGIES“ Taking action to power a circular

economy ensures our solar panels stays
sustainable and as clean as the energy
they produced, even after they havereached the end of their lifecycle.”
Zach Campeau
Director of Products

For any questions on this Report, please contact esg@maxeon.com.
To find out more about our ESG commitments, visit our webpage here.
18© 2023 MAXEON SOLAR TECHNOLOGIES