Modern Slavery
Statement

2022

Confidential | © 2023 Maxeon Solar Technologies, Ltd.

1

Table of contents
Our second modern slavery statement

3

Our initiatives: social supply chain audits

17

Third party collaborations

18

Grievance mechanism

19

Modern slavery risks

4

Our operations

4

Risks in our operations

4

Measuring effectiveness20

Our supply chain

52022 results

20

Risks of modern slavery in our supply chain

6

Risks of modern slavery in our supply chain Tier One non-affiliated suppliers

72022 Performance highlights andlooking forward

21

At the factories

8

Sustainability report

21

In the supply chain

9

Conflict minerals report

21

STACS partnership

22

Looking forward

23

Forward-looking statements

24

Actions to address the risks of modern slavery

10

An overview

10

Our policies

11

Our initiatives: for our employees & suppliers

12

Our initiatives: supply chain policies and governance13

Our initiatives: Conflict Minerals Policy

14

Our initiatives: traceability

15

Our initiatives: due diligence and audits

16

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Our second modern slavery statement

As a global company with a complex supply chain, we recognisethat risks of modern slavery exist within our business.
Understanding and managing these risks requires a collaborative
approach with our workforce, suppliers and other stakeholders.
This is why we are proud to make this public statement of ourvalues, policies and commitments.
This is our second Statement (the “Statement”) in response to theModern Slavery Act 2018 (the “Act”) in furtherance of our pledge touphold these values as a participant in the United Nations Global
Compact and as our position as the industry leader in oursustainability practices as demonstrated by being named by
Corporate Knights as one of the World’s Top 100 Most Sustainable
Companies.
The ‘reporting entity’ for this Statement is SunPower Corporation
Australia Pty. Ltd. (ACN: 009 066 380 ABN: 67009066380)(“we”,“our” or “SunPower Australia”).

This Statement is made voluntarily for the reporting period 1 January2022 to 31 December 2022. This Statement outlines how we identify andassess modern slavery risks in our operations and supply chain, theactions we have taken to address those risks and the progress we havemade to improve our understanding and effectiveness of the
management of modern slavery and human trafficking risks.
SunPower operates using Maxeon group-wide policies and procedures toassess and manage modern slavery risks. The adoption of these policies
is not intended to convey how we are structured, managed or controlled.
This Statement was approved by our Board of Directors on
28 June 2023.
If you have any questions about this Statement, please contact Matthew
Kasdin, Director, Senior Counsel and Deputy Chief Ethics and Compliance
Officer at matt.kasdin@maxeon.com.

Signed by:

Our corporate address is:
Suite 207/28 Riddell Parade
Elsternwick, Victoria
Australia 3185
1 800 786 769
SunPower Australia does not own or control any other entities.
We are an indirect but wholly-owned subsidiary of Maxeon Solar
Technologies, Ltd., a Singapore incorporated company listed on
the NASDAQ (collectively with its affiliates, “Maxeon”).

Chris O’BrienManaging Director SunPower Corporation Australia Pty. Ltd.

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Modern slavery risks
Our operations

Risks in our operations

SunPower Australia employs 29 staff located in Victoria,
New South Wales, Queensland and Western Australia.
Management in Australia leads the sale of goods into the AsiaPacific region and occasionally other markets. We have a regional
office in Melbourne, Victoria, and staff outside of Melbourne work
remotely. Our staff cover a range of functions in Australia:
Management (3 staff across VIC, and NSW), Sales (5 staff across
VIC, and NSW), Marketing (2 staff in VIC), Finance Sales
Operations & Administration (4 staff in VIC), Legal (1 staff member
in VIC), Channel Management (1 staff member in VIC), Supply
Inventory Optimisation Planning, Planning & Joint Venture
Operations (1 staff member in WA) and Fulfilment & Customer
Care (3 staff members in VIC).

To assess the risk of modern slavery in our operations, we
completed an initial desktop assessment. This included ananalysis of (i) the local conditions in the country where we
employ workers; (ii) the qualifications and status of theworkers we employ; and (iii) any other red flags that came toour attention (through consultations with specialist third-party
service providers, media, grievance mechanisms, etc.). We takereference from the Global Slavery Index1 while assessing therisks of modern slavery in the countries where we operate.

We sell a range of solar panel solutions for residential power (forexample, rooftop solar panels) and commercial power applications(for example, providing solar panels to solar power plants
including the Limondale 394 MW plant located in Balranald inregional NSW) and specialty products unique applications (such as
space and electric vehicle applications).
Our brands include the Maxeon (IBC), Performance (Shingled
Mono Perc) and Air product lines manufactured by Maxeon(Maxeon and Air) and its 15% owned joint venture Huansheng
Photovoltaic (Jiangsu) Co., Ltd. (“HSPV”) (Performance) and
Huansheng Solar New Energy (“HSNE”) where Maxeon has two
Board seats and has an agreement to sell offtake outside of China.

The risk of modern slavery in our operations is assessed to below. First, Australia is considered a low-risk country for modern
slavery. Second, our workforce comprises entirely highly
credentialed and experienced professionals that are not of
the profile for being at risk of modern slavery. We occasionallyemploy workers on a temporary basis but not in roles of anature considered to involve risks of modern slavery.
Finally, no red flags were identified in our operations
during the reporting period.

SunPower’s Limmondale Solar Farm in Balranald

For the avoidance of doubt, when we are speaking of our
supply chain, it is the Maxeon supply chain overall whenin doubt.

1 Available at www.globalslaveryindex.org. Note that data is from 2023.

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Modern slavery risks
Our supply chain
Top ten suppliers locations (%)

With the exception of solar panels (which are sourced from Maxeon and HSPV as discussed below), themajority of goods and services relating to our supply chain are sourced from vendors based in Australia.

Tier One suppliers

Tier Two suppliers

We have 80 Tier One suppliers located in Australia,
which is one of the top 10 locations we source from.
These suppliers provide services that enable ourmarketing, sales and distribution functions. Freight
is by far the biggest component, followed bycontractors for performing our warranties andconsultants.

In this statement, we have focused on
Tier Two suppliers of raw materials andcomponents for the solar products that we sell.
This is because we consider these to be some ofthe higher risk suppliers deeper in our supply
chain, and because we have access to relevant
information given our subsidiary relationshipwith Maxeon.

We source the solar panels we sell exclusively fromour parent company, Maxeon, and its joint venture
partner HSPV. These sales are booked
through Maxeon’s affiliates Maxeon Solar Pte. Ltd.
and SunPower Systems Sarl acting as agents,
which are located in Singapore
and Switzerland, respectively.

Maxeon produces its SunPower Maxeon cells in
Malaysia and the Philippines, and solar modules
in Malaysia and Mexico. Maxeon has more than
5,000 suppliers within its supply chain globally.
The top ten direct suppliers for Maxeon (in orderof size) are located in the Malaysia, UnitedStates, Mexico, Philippines, France, Singapore,
China, Australia, Germany and South Africa.

Denmark
3%

South Africa
2%Austral…
China
6%
Malaysia
20%

Singapore
9%

United States
16%

France10%

Philippines
15%

Mexico15%

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5Modern slavery risks
Risks of modern slavery in our supply chain
Over 98% of Maxeon's suppliers
originates from the 23 countries
shown in the map:

United Kingdom
30 Suppliers
Netherlands
28 Suppliers

United States
317 Suppliers*Remaining 2% ofMaxeon's suppliers originatesfrom these 20 countries:
Chile, Turkey, Thailand, Brazil,
Ireland, Malta, Canada, New
Zealand, Norway, Samoa,
Austria, Mauritius, Indonesia,
Finland, Latvia, Bermuda,
Portugal, Belize, Qatar andGreeceGlobal slavery index 20231:
Prevalence of modern slavery

Mexico309 Suppliers

Poland5 Suppliers

Belgium
13 Suppliers

Germany
58 SuppliersFrance207 Suppliers

Switzerland
28 Suppliers

Spain
17 Suppliers

Italy
41 Suppliers
Israel4 SuppliersSouth Korea
11 Suppliers

China
115 SuppliersIndia
16 Suppliers

Hong Kong
13 Suppliers

Malaysia
395 SuppliersJapan
45 Suppliers
Taiwan9 Suppliers
Philippines
289 Suppliers

Singapore
184 SuppliersSouth Africa
48 Suppliers

Australia
80 Suppliers*None of our Chinese suppliers are in Xinjiang, UAR

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Modern slavery risks
Risks of modern slavery in our supply chain Tier One non-affiliated suppliers
Our non-affiliated Tier One suppliers provide services
to us in Australia such as administrative, professional,
logistics and other related services. Most suppliers areeither large international logistics companies or local
suppliers in Australia in industries considered low risk.
Australia is considered a low-risk jurisdiction, ranked
as a low-risk jurisdiction on the Global Slavery Index.
We consider these suppliers to have a low level of risk
because these industries are not considered high riskin the Australian context. In addition, we screen all
suppliers before engaging them and ensure all of our
suppliers abide by our Code of Conduct through ourcontracts with them.

To assess the risk of modern slavery of our suppliersof solar products, we completed an initial desktop
assessment based on publicly available materials,
including the Global Slavery Index, various
ESG/human rights newsletters and websites, andparticipation in the UN Global Compact. This included
an analysis of (i) the local conditions in the country
where we employ workers; (ii) the qualifications andstatus of the workers employed; and (iii) any other red
flags that came to our attention (throughconsultations with specialist third party service
providers, grievance mechanisms, etc.). Where risks
came to our attention, we took further steps as
described in this Statement.

Our Reference Point:

We have conducted a risk assessment of our supply
chain on the basis of our Tier One Suppliers (ourAustralian suppliers, Maxeon and HSPV/HSNE) andour Tier Two Suppliers (the suppliers of Maxeon and
HSPV/HSNE).

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Modern slavery risks
At the factories
Maxeon Solar Technologies

HSPV / HSNE

Maxeon’s operated facilities in Malaysia and the Philippines are
considered to be at low risk of modern slavery by the Global
Slavery Index. This assessment is reaffirmed by the nature of
the local workforce (not having low skilled contract workers),
the measures Maxeon takes to onboard employees, the strengthof the local regulatory regimes, and the lack of historicalallegations. All Maxeon employees and contractors are required
to complete onboarding training, followed by annual training
in the subsequent years. They are also required to sign theaccompanying Annual Acknowledgment of Support. As part of
the acknowledgment, both employees and contractors will be
asked to confirm that they are not aware of any violations of
Maxeon’s Code, including human rights.

HSPV is assessed to have medium risk as China is rated
Medium risk on the Global Slavery Index. HSPV’s operations
are located in Yixing city, Jiangsu Province far from theallegations of force labour that are the subject of scrutiny of
the solar industry as are its suppliers which are not located in
Xinjiang. We have had no allegations of modern slavery at
HSPV/HSNE's or its suppliers. Furthermore, audits have notuncovered any deficiencies in HSPV/HSNE's practices in thepast. HSPV's medium risk is therefore only on account of theseriousness of the allegations of what is allegedly happening
elsewhere in China and not because we consider HSPV/HSNE
to have any direct exposure to such allegations.

The one location of Maxeon’s assessed to be at medium risk ofmodern slavery is Mexico (according to the Global Slavery Index).
We closely monitor and mitigate any risks and consider the riskof any infractions at our Mexican sites to be low due to ourefforts, although we remain vigilant and regularly update
our measures.

Maxeon’s
Operated Facilities
Maxeon’s Operated Facilities
Philippines

Malaysia

Medium Risk of Modern Slavery

Summary
The two medium risk assessments identified for China and
Mexico are inherent risks based on industry and country risk
under the Global Slavery Index. The assessment is not based on
any specific characteristics of the operations of HSPV/HSNE or
Maxeon. We consider neither location to have any special riskthat is not already addressed with robust procedures.

MexicoChina

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Modern slavery risks
In the supply chain
Due to the widely understood high-risk nature of
the solar industry supply chain, and the access
we have to information given our subsidiary
relationship with Maxeon, we have also
assessed the risks of modern slavery of our TierTwo suppliers of Maxeon and HSPV/HSNE basedon: (i) what is being supplied; and (ii) from where
it is being supplied. Informing this assessment
are publicly available materials such as the
Global Slavery Index, various ESG/human rights
newsletters and websites, and participation in the
UN Global Compact, among others.
In our industry, which relies heavily on raw
materials, the greatest risks of modern slavery inTier Two suppliers are identified as the suppliersof (i) tungsten, tantalum, tin and gold (3TG); and(ii) metallurgical grade silicon (MGSi), which form
part of our supply chain.

3TG - are identified internationally as natural resources
which have a high prominence of extraction from conflictzones and are often sold to perpetuate and fundconflict. Much of the labour involved in extracting
conflict minerals is child and forced labour. The mostprominent contemporary example has been the eastern
provinces of the Democratic Republic of the Congo.
MGSi - there is an industry-wide risk of MGSi which
relates to allegations of modern slavery in MGSi.
We do not source any MGSi from China (and in particularanywhere subject to allegations of forced labour), andneither do any of our suppliers’ suppliers, to the best of
our knowledge following our due diligence processes as
described in this document.

Aluminium - the aluminum supply from China has
been linked to Xinjiang province. As a result, we have
put a strong focus to mapping and stress-testing ouraluminum supply chain to ensure visibility on theprovenance and ensure no exposure to Xinjiang
province, UAR.
50

Sn
Tin
118.71173

Ta
Tantalum180.9574

W
Tungsten
183.8479

AuGold
196.967

Briefing on frame production process
Upstream activities

Aluminium
ingots

Al2O3

Bauxite mining andalumina refining

Aluminium
smelting

Aluminium
casting

Alloy rods/billets(6000-series alloys
used for PV frames)

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Actions to address the risks of modern slavery
An overview
We believe that people are at the heart of our operations at Maxeon,
which is why modern slavery is such an important focus for us as acompany. We strive to integrate our purpose of Holding Ourselves to a
Higher Standard throughout our business operations and supply chain, forthe benefit of our employees, our partners and the communities where
we operate. When we say 'our' on these pages, we speak of Maxeon which
includes for the avoidance of doubt SunPower Australia.
In addition to creating a safe workplace for our employees, we actively
seek to build a diverse pipeline of talent, retain well-performing staff
and create an environment where employees can fulfil their potential
without any risk of modern slavery. It is important for us to develop our
employees, provide competitive employee benefits, and ensure fair andsafe working conditions so that we have an engaged workforce who areproud to work for Maxeon.

Occupational
health andsafetyFair labourand humanrightsPowering positive change

Community
investment

Employees,
suppliers andcommunity

Employeeengagement

Externally, we strive to be a responsible corporate citizen by contributing toand supporting the communities where we operate. For our suppliers within
our value chain across the globe, we emphasise that human rights and fairlabour conditions are central to upholding our operational integrity.

Diversity andinclusion

Learning anddevelopment

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Actions to address the risks of modern slavery
Our policies
Board

Global human rights

The Maxeon Board of Directors delegates part of its responsibilities
to the following committees: the Audit Committee, the Compensation
Committee, the Coordination Committee, and the Nominating andCorporate Governance Committee. Our ESG strategies, initiatives
and performance are governed by our Nominating and Corporate
Governance Committee, and are supervised by our Executive
Leadership Team (ELT). As we strive towards remaining abreast of
macro ESG trends, opportunities and risks, our Global ESG team andChief Legal Officer, who is also our Chief Sustainability Officer,
provide quarterly updates and presentations to the Committee on
global ESG shifts, as well as our own ESG initiatives and progress,
and this includes the social domain such as human rights andmodern slavery risk.

Fair labour practices and respect for human rights arepromoted across our global network of operations for all
employees, workers in our supply chains and individuals
in the community.

The policy is informed by global best practices
and guidelines including the following:

Maxeon's Global Human Rights Policy establishes
standards for our global business conduct related tohuman rights and labour for employees, suppliers andany other business partners, and is made publicly
available through our various stakeholder engagement
platforms, including our website.

• Universal Declaration of Human Rights• Conventions of the International Labour
Organization (ILO)• UN Guiding Principles on Business andHuman Rights• UN Global Compact• Organisation for Economic Co-operation

and Development (OECD) Guidelines forMultinational Enterprises

The following dimensions are addressed across our policy:
Non-discrimination

Freedom of association

Non-harassment

A safe and conducive workplace

Forced or child labour

Maxeon upholds a merit-based work
environment and expressly prohibits
discrimination in the workplace. Maxeon
supports minority and indigenous persons’rights in the countries where we operate,and expects our suppliers to do the same.

Maxeon respects the rights of all
workers to associate freely, including
joining labour unions, seeking
representation and establishing joint
workers’ councils, under theconditions that local laws arerespected and adhered to.

Maxeon prohibits engagement in any
form of harassment including but notlimited to status-based harassment,
sexual harassment and mental or
physical coercion or verbal abuse ofworkers. Maxeon also prohibits thethreat of any such treatment.

Maxeon works to ensure that theworkplace is a safe and conducive
environment for everyone. This includes
a cap on the number of hours worked ina week, fair compensation plans andrigorous safety practices.

Maxeon prohibits any form offorced or child labour, including
modern slavery and humantrafficking.

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Actions to address the risks of modern slavery
Our initiatives: for our employees & suppliers
For our employees

For our suppliers

Our employees are made aware of our Code of Conduct andWhistleblower policies through their employment contract,annual compliance training, certification and courses, which
include a module on modern slavery, that is compulsory for
all managers.

Our suppliers and their relevant agents are required toadhere to the Code of Conduct and thereby, uphold thehighest standards of ethics. This is embedded in all ourcontracts.

Our compliance and ethics helpline is available 24/7 online orby phone for both internal and external stakeholders toreport any known or potential violations of applicable laws or
breaches of the Code of Conduct. To ensure inclusivity, webbased reports may be submitted anonymously, and in any
language. We engage an independent third party to assist in
administering the helpline.
Our process for corporate compliance includes the creationof a whistleblower report, which is subsequently assessed by
an executive-led committee and investigated based on thenature of the incident. If required, we engage external
consultants, such as lawyers, accountants or otherspecialists. Ultimately, all reports are reviewed by our audit
committee, and remediation actions are determined on acase-by-case basis.

Our standard supplier contracts and purchase orders containlanguage requiring compliance with our modern slavery
standards and providing for termination in the case of aviolation of such standards.
In addition, we also expect our suppliers to adopt or
establish their own internal management systems to fulfil therequirements of our Supplier Sustainability Guidelines, which
are signed by each of our suppliers as part of the onboarding
process. This management system ensures that the supplier’s
operations and products are compliant with our guidelines,
as well as all laws, regulations and customer requirements.
Additionally, the supplier management system will assist in
the identification and mitigation of operational risks
pertaining to our guidelines while facilitating
continual improvement.

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Actions to address the risks of modern slavery
Our initiatives: supply chain policies and governanceMaxeon requirement
Our suppliers•••

Code of business ethics and conduct
Supplier’s sustainability guidelines
Live training

Our suppliers’ suppliers

Policies for employees & contractors:•••• Code of business ethics and conduct

Code of business ethics and conduct
Supplier’s sustainability guidelines
Enhanced certifications for China-exposed suppliers
regarding not being (i) in Xinjiang; and (ii) on OFAC
list of sanctioned entities (which includes the entities
alleged to be involved in forced labour)• Whistleblower hotline

Zero-tolerance
policy for breach
Suppliers will beterminated if found in
non-compliance oflabour standards

Our suppliers’ suppliers••

SEIA Protocol
Working MOP

We commit as a matter of practice tocomplying with the most stringent laws andinternational best standards.

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Actions to address the risks of modern slavery
Our initiatives: Conflict Minerals Policy
Through Maxeon’s Conflict Minerals Policy, we are committed to avoiding
the use of conflict minerals that directly or indirectly finance or benefit
armed groups in the Democratic Republic of Congo (DRC) or adjoining
countries, while continuing to support responsible mineral sourcing in theregion. Conflict minerals include: columbite-tantalite (coltan) (i.e., tantalum),cassiterite (i.e., tin), gold, wolframite (i.e., tungsten) or their derivatives(3TG), and could expand to include other minerals or their derivatives.
To support this policy, Maxeon has committed to seven key principles(see graphic).
Suppliers identified as having a reasonable risk that they are sourcing fromor linked to any party providing direct or indirect support to non- statearmed groups will immediately undergo detailed investigations by Maxeon.
Should any breaches to the Conflict Minerals Policy arise, remediation
measures will be undertaken which can include suspension or
discontinuation of the engagement.
See our most recent Conflict Minerals Report here.

01

Require concerned suppliers to declare that all products supplied either do notcontain 3TG that are necessary to their production or functionality, or, if they do,that they originate from non-conflict areas or from refiners or smelters that havebeen validated as being conflict-free.

02

Commit to adopt, widely disseminate, and incorporate this policy in contracts
and agreements with suppliers who may source the concerned minerals.

03

Require all Maxeon suppliers to acknowledge
Maxeon’s Supplier Sustainability Guidelines.

04

Carry out due diligence consistent with the OECD’s recommended process.

05

Reserve the right to request additional documentation from suppliers regarding
the source of any minerals included in its products, and ask for traceability data
to be maintained for a minimum of five years.

06

Coordinate with other companies to create better reporting solutions.

07

Ensure transparency of the conflict minerals reporting process
by making our reports publicly available.

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Actions to address the risks of modern slavery
Our initiatives: traceability
In accordance with emerging regulations and best practices,
Maxeon has implemented measures to trace its supply chain.
In principle, Maxeon is following the procedures set forth in the
SEIA Protocol and has formed an internal taskforce toimplement the protocol. This involves taking the following steps:

01
02
03

Identifying the source of raw materials incorporated
in products;
Tracing such raw materials every step from thesource through the factories where it isprocessed until it is delivered; andUse of Manufacturer’s Execution System (MES)
tracing system as well as transportation
documentation every step of the journey.

Polysilicon

Ingot

Wafer

Cell

ModuleMining of
MGSi /
Polysilicon
production

Factory
location

Factory
location

Factory
location

Factory
location

Due
Diligence/
Certification/ Tracingfrom source
to factory

On the right is a sample of what Maxeon products tracing
the MGSi / Polysilicon looks like, which is a key area of
scrutiny in our industry.
13

Al
Aluminium
26.9815386

Transport documents, Manufacturer’s Execution System (MES),
Supported by internal and third-party audits

Update:Maxeon is now providing extra scrutiny to aluminum in
addition to MGSi to ensure that none of its aluminum has
any inputs from Xinjiang / forced labour

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Actions to address the risks of modern slavery
Our initiatives:due diligence and audits
Chain of custody audit
A chain of custody audit for traceability goes throughevery step of the process to ensure inputs are tracked
from the source of the raw materials to the final productreceived by the customer.
Focus is on documentation such as purchase orders andtransportation documents and systems to track lot
numbers at factories such as usage of Manufacturer’s
Execution System (MES).

Social audit
These audits focus on working conditions at a factory,compliance with forced labor laws and other ESG factors
in a holistic evaluation of the site audited.
One leading standard is the SMETA (Sedex Members
Ethical Trade Audit) methodology, the most widely used
format for social audits in the world.
It is challenging but we are seeing that these audits canbe conducted in China at present with the rightparameters and sensitivity to the local context.

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Actions to address the risks of modern slavery
Our initiatives:social supply chain audit
Ethical and responsible sourcing

Pre-audit• More than 60,000 member organisations from over 180
countries use Sedex’s online platform to operate
responsibly and sustainably, protect workers and ensureethical sourcing.
• Maxeon has engaged an audit firm to audit supply chain
operations and working conditions. The audited results
are uploaded on the Sedex platform.
• All registered members of Sedex can request for a copyof the audit report from Sedex via the platform.

Supplier completes theSedex Self-Assessment
Questionnaire (SAQ)
Supplier shares existing
audits, including the SAQ,
with buyer
Buyer reviews inherent risk
score in Sedex risk
assessment tool
Buyer prioritizes suppliersites and defines
requirements for audit

Audit

Post-audit

SMETA process assesses asite’s standards of labour,
health and safety,
environment and businessethicsSupplier and buyer review
final audit report on Sedex
digital platform to assess
findings and areas of noncompliance

Auditor will conduct
supplier site visit,
consisting of a site tour,
interviews, and document
review

Supplier and buyer work
to resolves corrective
action, auditor ultimately
verifies resolution

Auditor will hold a closing
meeting to review the
Corrective Action Plan
ReportOnce a site undergoes a
SMETA audit , supplier canshare report with othercustomers via the Sedex
platform

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Actions to address the risks of modern slavery
Third-party collaborations
We are an active member of industry groups that work to combat modern
slavery in our industry.

• Clean energy council: we are a member of the Modern Slavery Working
Group of Australia's Clean Energy Council. At such working group,
we participate in the discussions shaping the future implementationof modern slavery legislation in Australia.

• Solar energy industries association: Maxeon is a member of SEIA's Trade

Working Group, which focuses on restrictions on importing solar products into
the United States that are made with forced labour.

• STACS (Hashstacs Pte Ltd): Maxeon has partnered with STACS to commenceon supplier sustainability monitoring via its ESGpedia platform. STACS's
ESGpedia powers the Monetary Authority of SIngapore's (MAS) Greenprint ESG
Registry and is Asia's leading ESG solution provider.

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Actions to address the risks of modern slavery
Grievance mechanism
As stated on our website:“If we become aware of any alleged breaches of our Global Human Rights
Policy, we take them seriously, and any violations will lead to termination.”

Employees, contractors and suppliers at Maxeon are encouraged to join the fight forhuman rights. A Compliance and Ethics Helpline is available 24/7 for internal andexternal stakeholders to anonymously report any concerns or infractions.

When issues have arisen in the past, we conducted a formal investigation andsuppliers have been terminated. Currently, there are zero cases of noncompliance with regards to human rights and fair labour issues, both within ourinternal operations as well as within our supply chain.
In addition to having a zero-tolerance policy for any violations of human andlabour rights, we continue to monitor current and emerging regulations andindustry best practices. We will continue to enhance our internal policies andcontrols and work with suppliers to ensure continued compliance with any
relevant laws, protocols and best practices as circumstances
may require.
For any high-risk countries identified in the future, we will work across our value
chain to mitigate risks through our multi-step risk assessment methodology
and, if necessary, engage specialists, both internal and external, to aid in risk
assessment and remediation measures, should
issues arise.

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Measuring effectiveness2022 results
One case of potential non-compliance was found in 2022 with regard to humanrights and fair labour issues. It was detected through an audit. We addressed
the issues identified through our remediation procedure and the corrections
were verified by a subsequent audit.
We continue to monitor current and emerging regulations and industry bestpractices. We will continue to enhance our internal policies and controls andwork with suppliers to ensure continued compliance with any relevant laws,
protocols and best practices as circumstances may require.
We are committed to reviewing the effectiveness of our policies on an annual
basis as part of the Maxeon Group wide review. In future years, we will seek todevelop frameworks and processes to ensure we can review the effectiveness of
the actions we are taking to assess and address modern slavery risks in ouroperations and supply chains.

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2022 performance highlights and looking forward
2022 in focus
Sustainability Report

Conflict Minerals Report

Maxeon published its third Sustainability Report in 2023. This
included our Board Diversity and Hiring Statement. We are also
recognized as a global leader this year being named in the top 1%
of public companies globally by Corporate Knights.

Maxeon released its 2022 Conflict Minerals Report which is available here.

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2022 performance highlights and looking forward
2022 in focus
STACS partnershipMaxeon and STACS embarked on the ESGpedia supplier sustainability
monitoring project to leverage holistic ESG data and digital tools on ESGpedia
for monitoring the sustainability performance of suppliers in Maxeon’s end-toend supply chain.
ESGpedia bridges the disconnect between the ESG data and digital tools thatcompanies need for effective supplier sustainability monitoring and decisionmaking, and what is available to them.
The ESGpedia platform enables Maxeon to select suppliers based on ESG
factors. This facilitates better tracking and analysis of suppliers’ sustainability
commitments, impact measurement, and quelling of greenwashing fears.

2

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1 SUPPLIER 1

SUPPLIER 1

SUPPLIER 2

SUPPLIER 2

SUPPLIER 3

SUPPLIER 3

SUPPLIER 4

SUPPLIER 4

SUPPLIER 5

SUPPLIER 5STACS' ESGpedia platform is also expected to enable financiers and investors
to make better green investment decisions, resulting in a positive ESG cycle.

Confidential | © 2023 Maxeon Solar Technologies, Ltd.

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2022 performance highlights and looking forward
Looking forward
We embrace a commitment to continuous improvement and plan to continue toenhance what we are doing to combat any possibility of modern slavery in ouroperations or our supply chain. Among the areas identified for improvement are
the following:
1. Enhanced trainings:
We plan to roll out enhanced trainings both to our employees and suppliers.
2. Enhanced communication of modern slavery policies:
We plan to continue to enhance communications regarding modern slavery
policies and developments both internally and also externally to educate thepublic about best practices.
3. Enhanced traceability:
Maxeon has mapped many of our raw materials to the ultimate source andwill continue to look at ways to enhance our controls over second and third
tier suppliers, such as through our Long-Term Target of supply chain on theblockchain below.
4. Scrutiny of high-risk countries/vendors:
Where these have been identified, such as described above, we will work
across our value chain to mitigate risks through our multi-step risk
assessment methodology and if necessary, engage specialists, both internaland external, to aid in risk assessment and remediation measures, should
issues arise.

Confidential | © 2023 Maxeon Solar Technologies, Ltd.

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Forward-looking statements
This Modern Slavery Statement contains forward-looking statements within themeaning of the Private Securities Litigation Reform Act of 1995, including, but notlimited to: statements regarding the Company’s financial and operating expectations,market leadership, customer value proposition and competitive advantages; theCompany’s strategic goals and plans, including relationships with existing customers,
suppliers and partners and our ability to maintain them; the legislative and regulatoryenvironment of the solar industry; the Company’s ability to manage supply chains andworkforce. These forward-looking statements are based on our current assumptions,
expectations and beliefs and involve substantial risks and uncertainties that may
cause results, performance or achievement to materially differ from those expressedor implied by these forward-looking statements. A detailed discussion of these factors
and other risks that affect our business is included in filings we make with the
Securities and Exchange Commission (“SEC”) from time to time, including our mostrecent report on Form 20-F, particularly under the heading “Item 3.D. Risk Factors.”
Copies of these filings are available online from the SEC or on the Financials & Filings
section of our Investor Relations website.
All forward-looking statements in this Modern Slavery Statement are based on
information currently available to us, and we assume no obligation to update theseforward-looking statements in light of new information or future events.

Confidential | © 2023 Maxeon Solar Technologies, Ltd.

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"'Holding Ourselves to a Higher
Standard' requires us to be
stewards of all the elements, fromminerals to human capital, thatare embedded in our products."
Matt Kasdin
Director, Senior Counsel, Deputy Chief Ethics and Compliance Officer

For any questions on this Report, please contact Matt Kasdin at
matt.kasdin@maxeon.com or esg@maxeon.com.
To find out more about our ESG commitments, visit our webpage here.
© 2022 Maxeon Solar Technologies