Trina Solar (Australia) Pty Ltd

2023 Modern
Slavery Statement
www.trinasolar.com/auIntroduction
Trina Solar (Australia) Pty Ltd (ACN 150 695524) (hereinafter referred to as “TrinasolarAustralia”), is a subsidiary of Trina Solar Co., Ltd.,a publicly listed Chinese company founded in 1997
(stock code: 688599.SH). Together with theirglobal affiliates, these entities will be collectively
referred to herein as “Trinasolar” or “TrinasolarGroup”.
Trinasolar is dedicated to upholding human andlabour rights and is committed to the global
eradication of modern slavery in all its forms.
For the financial year ending on 31 December
2023, Trinasolar Australia reported revenues
exceeding one hundred million Australian dollars,surpassing the threshold established by theModern Slavery Act 2018 (Cth) (hereinafterreferred to as the “Act”) and, as such, is classified
as a reporting entity pursuant to the Act.

This statement outlines the areas of risk identified
by Trinasolar, the initiatives undertaken to
mitigate these risks, and the measures employed
to assess the effectiveness of these efforts ineliminating the risk of modern slavery within itsoperations and supply chain.
Trinasolar actively collaborates with its suppliers
and stakeholders to increase awareness ofmodern slavery issues. The company is committed
to effectively communicating its expectations
and, when necessary, taking decisive action toaddress and eliminate any risks associated withmodern slavery.

According to the Act, “modern slavery”
encompasses the following categories:• Trafficking in persons;• Slavery;• Servitude;• Forced labour;• Debt bondage;• Deceptive recruiting for labour orservices; and• Child labour.

Trina Solar (Australia) Pty Ltd 2023 Modern Slavery Statement

01About Trina Solar (Australia) Pty Ltd
Trinasolar Australia is the Australian arm of Trinasolar Group, whose parent company,
Trina Solar Co., Ltd. has its headquarter in Changzhou City, Jiangsu Province, China.
Trinasolar Group is the world’s leading photovoltaic (“PV”) and smart energy totalsolutions provider.
Trinasolar Group is mainly engaged in thefollowing sectors:•Research and development, production andsales of PV modules, trackers and energy
storage products;•Development of PV power stations and systemproducts;•Provision of PV power generation, operationand maintenance services; and•Development and sales of intelligent
microgrids and multi-energy systems, as wellas the operation of energy cloud platforms,
amongst other initiatives.

Trinasolar Group is committed to pioneeringsmart solar energy solutions aimed at achievinga net-zero future. Through constant innovation,
Trinasolar Group continues to push the PV industry
forward by creating greater grid parity of PV power
and promoting the adoption of renewable energy.
Trinasolar Group is consistently recognised asa top-tier PV module manufacturer globally. Inaddition, Trinasolar Group’s downstream businessincludes solar PV project development, financing,design, construction, operations, management
and comprehensive system integration solutions
for customers.
Trinasolar Australia employs thirteen (13) fulltime employees ranging from sales personnel tosolar engineers, finance experts to support staff.
On a global scale, Trinasolar Group has nearly
fifty thousand (50,000) employees. Trinasolar
Group’s module shipments consistently rank
in the top three within the industry. In 2023,
Trinasolar Group’s module shipment volume was65.21GW, marking a 51.3% increase year-overyear. By the end of 2023, Trinasolar Group had
supplied intelligent tracking solutions for over700 PV power stations in more than 60 countries

around the world, with cumulative shipments offixed structures and tracker products exceeding
20GW. Trinasolar Group has established regional
headquarters in Zurich, Fremont (Silicon Valley),
Miami, Singapore, Dubai, UAE, as well as offices
and branch offices in Australia, South Korea, India,
the UAE, Turkey, Italy, Germany, Spain, the UK,South Africa, Brazil, Chile, Colombia, and Mexico,and overseas manufacturing bases in Thailandand Vietnam. In recent years, Trinasolar has
recruited international high-level management
and R&D talents from more than 70 countries,
and the business has spread to over 170 countries
around the world.
Trinasolar Australia supplies solar panels toengineering, procurement and construction (EPC)
project partners, solar farm constructors, andwholesalers. All Australian employees are hired
under lawful labour contracts in accordance withlocal regulations and are free to associate withunions of their choosing.
Trinasolar Group is committed to corporate social
responsibility (CSR), including the elimination of
all forms of modern slavery, and adheres to ethicalbusiness practices in compliance with applicablelaws, rules, and regulations in all operationalregions. This commitment is supported by its
Code of Business Conduct and Ethics, Social
Responsibility
Management
Regulation,
Trinasolar Global Human Rights Principles,
employee handbook and various other guiding
principles that govern its supplier verification andhuman resource management systems.
Trinasolar Group believes in being fullytransparent with all partners and local authorities
and continues to refine its tools to effectivelyaddress any and all potential risks associated withmodern slavery.

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02

Trinasolar’s Supply Chain
Trinasolar’s supply chain covers
various types of procurement
products that can be classified into
the following categories:• Raw materials;• Auxiliary materials;• Infrastructure;• Equipment;• Accessories;• Packaging;• Logistics;• Transportation;• Labour protection supplies;• Office supplies; and• Third-party certification services.

Trinasolar‘s suppliers, primarily located in China,
Germany, Malaysia, Spain and Vietnam, arecentrally managed by Trinasolar Group’sprocurement department in China. The company
has developed and implemented the Trinasolar
Supplier Code of Conduct, Supplier Environment,
Health and Safety (EHS) and CSR Management
Procedure,Identification
andTraceability
Management Guide as well as the Procurement
Management Guidelines to provide directions forthe full lifecycle supplier management. It includes
environmental, social, and governance- (ESG)
related clauses in its procurement contracts withsuppliers. During the reporting period, thecompany revised the Trinasolar Supplier Code ofConduct to emphasise that suppliers should
obtain and maintain ISO 14001, ISO 45001 andISO 50001 certificates, or plan to obtain them, orhave effective EHS and energy management

systems. In 2023, it further required suppliers tocommunicate its environmental and human rights
requirements, as set out in the Trinasolar Supplier
Code of Conduct, and the ESG-related clauses inthe contract to their upstream supply chains.
Trinasolar
Groupowns
andoperates
manufacturing production plants in the cities ofChangzhou, Suqian, Yiwu, Yancheng, Huaian andQinghai in China, as well as Vietnam and Thailand.
Trinasolar Group is expanding its global footprint,
with new manufacturing projects underway
in the United States, Indonesia and the UAE,
and aims to enhance its global capabilities andcompetitiveness in overseas markets.
In 2023, significant progress was made on theconstruction of the Qinghai manufacturing facility
in Qinghai province, China. This facility aims topioneer the integration of a complete PV industry
chain and establish a zero-carbon industrial parkin Xining, Qinghai (herein referred to as the “TrinaQinghai Facility”). The first phase of this project,including the production lines for solar ingots,wafers, cells, and modules, has been completed
and is now operational. The Trina Qinghai Facility
is poised to reach full production capacity, startingwith MG silicon, in the near future.
To develop and identify ethical suppliers, local
employment and labour rights protection are
critical aspects for Trinasolar in ensuring modern
slavery risks are completely nullified throughout
its global supply chain. As a prerequisite forapproval, all potential suppliers must demonstratecompliance with local labour laws before they canbecome a qualified vendor for Trinasolar Group.
Further details on policies, measures, and actions
taken by Trinasolar to address these issues
are discussed in subsequent sections of thisstatement.

Trina Solar (Australia) Pty Ltd 2023 Modern Slavery Statement

03Modern Slavery Risk Management
Trinasolar Group has classified modern slavery risks into external and internal
categories. The external modern slavery risks are managed by Trinasolar
Group’s procurement team while any intercompany risks are managed
by the human resources as well as legal and compliance departments ofTrinasolar Australia, which work closely with Trinasolar Group as a whole.

Areas of risks identified by
Trinasolar within its business
operations include:• Raw material suppliers;• Storage and logistical providers;• Trinasolar-owned and OEM factories;• Distributors;• Installers;• EPC providers or developers for solar
projects;• Research and development partners;• Shareholders;• Consumers (end-users); and• Employees.

Supplier risks are managed through Trinasolar
Group’s internal procurement practices andthe robust supplier performance evaluation
system in the supplier selection process.
Trinasolar has established different selection
principles and qualification standards to fulfil
various procurement needs. It issues a Supplier
EHS and CSR Audit Checklist with ESG-related
questions to prospective suppliers. Basedon the returned questionnaire, the company
assesses their compliance, environmental andsocial performance, and relevant qualification
documents. In addition, it requires suppliers

and partners to sign the Trinasolar SupplierSocial Responsibility Agreement. This document
specifies that all suppliers and their supply chainsmust understand and comply with Trinasolar’s
policies on environmental, occupational healthand safety, social responsibility and resource
management, as well as the Trinasolar Supplier
Code of Conduct. As part of this evaluation
process, Trinasolar actively collects dataand information from suppliers such as theiremployee turnover ratio, any reported health orcode of ethics breaches, and a number of otherkey metrics to ascertain the suppliers’ levels ofemployee satisfaction.
All information provided by suppliers is rigorously
assessed against the Trinasolar Supplier Code ofConduct. Non-compliance with the set criteria
requires immediate remedial action by thesuppliers; failure to do so will result in their
immediate suspension.
Internally, Trinasolar Group’s human resources
department regularly updates the company’s
employee handbook to ensure the latest labourlaws and the rights of employees can be addressed
timely in the workplace. Additionally, it offers
online courses to all employees and conducts
an annual engagement survey to measureemployees’ views on various aspects such asfair treatment, health and safety, benefits, andtraining opportunities. These initiatives help
maintain its commitment to fostering a respectfuland ethical work environment.

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04

Policies and Governance
Trinasolar is deeply committed to upholding
internationally recognised human rights principles
across its operations and throughout its valuechain. This commitment extends to the Universal
Declaration of Human Rights, United Nations
Global Compact (UNGC), the ILO Declaration onFundamental Principles and Rights at Work, theOrganisation for Economic Co-operation andDevelopment (OECD) Guidelines for Multinational
Enterprises, the UK Modern Slavery Act 2015, theAustralia Modern Slavery Act 2018 and the lawsof the countries in which Trinasolar operates. It is
dedicated to integrating these universal humanrights principles into its strategies, policies andprocedures, thereby establishing a culture ofintegrity that is foundational to its long-term
success.
To manage and mitigate modern slavery risks,
Trinasolar has established an integrated
management system across its operations. It
is continuously committed to maintaining andenhancing this system to prevent any potential
risks of modern slavery or other human rights
violations. Its approach includes the following
policies, regulations, and procedures designed toaddress these risks and ensure compliance withglobal human rights standards:

1) D ocuments accessible on its
official website:a) Trinasolar Social ResponsibilityManagement Regulationb) Trinasolar Global Human RightsPrinciplesc) Reconfirmation of the ProductStewardship Policyd) EHS and Energy Management Policye) 2023 Sustainability Report2) Documents available uponrequest:a) Trinasolar’s Supplier Code of Conductb) T rinasolar’s Code of Business Conductand Ethicsc) Procurement Management Guidelinesd) EHS and Energy Management Policye) S upplier EHS & CSR ManagementProceduref) EHS Management System & CSR
Internal Audit Management Procedure

Trinasolar Group rigorously ensures that its
products and supply chains are free from any
materials that have been produced, manufactured
or provided using any form of forced labour orslavery. It has established a dedicated teamresponsible for developing and monitoring
compliance with all modern slavery regulations.
This team includes:•

Internal Audit;•Global Compliance;•Legal Department;•

Human Resources;•Procurement;•

Quality Control; and•

Brand Management.

Trinasolar Group publishes its CSR report basedon standard social responsibility assessments
integrated with results from annual inspections
and evaluations of all its suppliers. Its global
procurement team vigilantly monitors its global
supply chain partners to ensure that they do not
engage in or support forced labour practices.

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05

Actions
Trinasolar Group diligently maintains andperiodically updates its Code of BusinessConduct and Ethics, which strongly emphasises
the protection of human rights and the fairtreatment of all workers. This Code, mandatory
for all employees, outlines the company’s corevalues and guiding principles, ensuring thatbusiness operations are conducted ethicallyand in compliance with all relevant laws, rules,
and regulations across the regions the company
operates in. All employees within Trinasolar Groupand the contractors and consultants who perform
work on Trinasolar’s behalf are provided withcomprehensive training on this Code to ensure
awareness of the risks associated with modern
slavery and human trafficking. This training is
mandatory for all new employees.

supplier performance evaluation. Trinasolar has
developed and implemented the Supplier EHS& CSR Management Procedure, which requires
procurement staff to record supplier performancein the Supplier EHS and Social Responsibility
Form. This form includes fifty-six (56) assessment
indicators of suppliers’ performance across five(5) areas: environmental protection, occupational
health and safety, fire safety and emergency
preparedness, labour and human rights, andbusiness ethics and sustainable procurement.

Trinasolar Group conducted from time to time
specialised compliance training for all overseas
employees, focusing on anti-fraud prevalence andTrinasolar’s Code of Conduct. This initiative wasdesigned to strengthen employees’ awarenessand understanding of their rights in the workplace
and to acquaint them with Trinasolar Group’s
principles and specific measures for protecting
human rights and ensuring fair treatment of all
employees.
Trinasolar Group evaluates suppliers on various
aspects, including labour use, social responsibility,safety, and environmental performance. Basedon these evaluations, it assesses and approves
suppliers, providing targeted communication,training and counselling. Suppliers that fail toeliminate detected risks will face restrictedprocurement
opportunities,
freezingorelimination.

For labour and human rights
assessment, the criteria focus on:
••
•
•
•
•

Commitments,policies,
orstatements regarding respect forhuman rights that comply with orexceed international and nationallaws and regulations;
Strict prohibition of child labour(including interns);
Strict prohibition of forced labour(including interns);
Freedomofassociation
andcollective bargaining;
Anti-discrimination; andEmployee rights and remuneration
management.

The Trinasolar Supplier Code of Conductemphasises environmental and social standards
for all suppliers and provides reporting channels
to encourage mutual monitoring. Suppliers’
ESG performance is fully integrated into theTrina Solar (Australia) Pty Ltd 2023 Modern Slavery Statement

06

Its standard supply and/or service agreements
include labour and legal compliance clauses toreinforce these commitments.

that provides customers with detailed reports on
the materials used in specific shipments of solarmodules.

Additionally, all Trinasolar Group and Trinasolar
Australia employees, and all third-party partners,
are always encouraged to report any suspectedviolations involving slavery or human trafficking,without fear of retaliation. Suspected incidents
can be reported directly to Trinasolar’s Compliance
Committee through a fully confidential
and anonymous hotline, or by emailing
scc@trinasolar.com.

Finally, all new suppliers must sign and execute
the Trinasolar Supplier Social Responsibility
Agreement confirming the lawful employmentof all their workers as a condition of becoming
a qualified supplier for Trinasolar Group. Thisagreement mandates the timely payment ofsalaries in accordance with local laws, provisionof insurance coverage for employees, adherence
to legal working hours, and a strict prohibition
against employing underage or forced labour.

Moreover, Trinasolar Group has enhanced its IT
traceability system for its customers with thePhegda Big Data System, a traceability system

Trina Solar (Australia) Pty Ltd 2023 Modern Slavery Statement

07

Valuation of Effectiveness
Trinasolar recognises that the risk ofmodern slavery is an ongoing concern
and is committed to continuous
efforts to mitigate these risks. To
accurately assess and enhancethe effectiveness of its strategies,
Trinasolar continues implementing
the following measures:• Ongoing reviews of key supplier
agreements to ensure they include
specific provisions addressing modernslavery;• Continued delivery of comprehensive
training programmes for all employees toheighten awareness of modern slavery
risks, supplemented by competence
evaluations to measure the impact andeffectiveness of the training;

Trinasolar Group’s commitment to sustainability
has been externally audited since 2014 by
EcoVadis, a leading independent auditor of
businesssustainability
ratings
worldwide.
Trinasolar Group has consistently achieved goodscores in its CSR performance, particularly inenvironmental protection and employee rights, asevidenced by numerous awards from EcoVadis. All
relevant certificates and accolades can be viewed
at https://www.trinasolar.com/au/our-company/sustainability-downloads). Trinasolar is also
certified under ISO45001 for Occupational Healthand Safety Management Systems and ISO37301
for Compliance Management Systems, further
underscoring its dedication to maintaining safe andethical working conditions and robust compliancemanagement system.

• Regular assessments and continuous
monitoring of responses to Trinasolar
Group’s supplier Know Your Customer(KYC) questionnaire; and• Encouragement of self-reporting fromTrinasolar Group and Trinasolar Australia’s
external partners regarding any identified
or suspected issues related to modernslavery.

Trina Solar (Australia) Pty Ltd 2023 Modern Slavery Statement

08

Continuous Improvement
Trinasolar acknowledges the importance of a zero-tolerance policy
towards modern slavery within its ecosystem and recognises theneed for ongoing improvements to its risk management system. To
this end, Trinasolar Group and Trinasolar Australia have pinpointed
several key areas for enhanced focus and future development:• Enhanced Engagement: Maintaining
continuous dialogue with employees,
external partners, and service providers
on all matters related to modern slavery
risks will ensure alignment with Trinasolar
Group’s expectations of Trinasolar Group as
well as compliance with all applicable local
jurisdictions.
• Code of Conduct Review: Regularexamination of industry codes of conduct
is essential to ascertain how these can bebetter integrated into Trinasolar’s practices,ensuring timely improvements are made.

• Process Automation: Exploration ofoptions for the automation and streamliningof processes between Trinasolar and its
suppliers through third-party solutions toenhance efficiency.
• Performance
Monitoring:
Ongoing
assessment of Trinasolar Group’s progress
and performance is critical, both internallyand externally, to ensure continuousimprovement.

Trina Solar (Australia) Pty Ltd 2023 Modern Slavery Statement

09

Process of Consultation with Any Entities
the Reporting Entity Owns or Controls
Trinasolar Australia does not own or control any other entities and is therefore not required to report under
section 16(1)(f) of the Act. However, during the preparation of this statement, it engaged in collaborative
discussions with various entities within the Trinasolar Group. These discussions focused on understanding
the reporting obligations of the Act, exchanging ideas on actions to fulfil these obligations, and ensuringthat all relevant parties were well-informed and provided with the latest materials and updates throughout
the process.

It remains at your disposal should you have any queries on the above.
This statement was approved and signed by Ms. Liu Teng as the Sole Director andprincipal governing body of Trina Solar (Australia) Pty Ltd.

Date Signed: 31 May 2024

Liu Teng
Sole Director of Trina Solar (Australia) Pty Ltd

Trina Solar (Australia) Pty Ltd 2023 Modern Slavery Statement

10General enquiries
Tel: +61 1300 874 627 Fax: +61 2 9199 8006
(Monday to Friday 9:00am to 4:30pm)
2 Banfield Road
Macquarie Park NSW 2113
ACN: 150 695 524

www.trinasolar.com/au