Trina Solar (Australia) Pty Ltd

2022 ModernSlavery Statement
www.trinasolar.com/auIntroduction
Trina Solar (Australia) Pty Ltd ACN 150 695 524 is committed to humanand labour rights and to the global eradication of modern slavery
in all its forms.
Trina Solar (Australia) Pty Ltd (ACN 150 695 524)
(hereinafter to be referred to as “Trina SolarAustralia”), along with its headquarter beinga China listed company and its global affiliates(collectively to be referred to as “Trina Solar”
or “Trina Solar Group”), is fully committed topreserving all human and labour rights and tothe global eradication of modern slavery in allits forms.

(hereinafter referred to as the “Act”) and, assuch, is classified as a reporting entity pursuant
to the Act. This statement highlights Trina Solar’sareas of risk, the actions that have been taken
or are being taken by Trina Solar to actively
address such risks, and how Trina Solarmeasures its effectiveness in eliminating therisk of modern slavery in connection with its
operations and supply chain.

During the course of the current reporting
period of financial year ending on 31st
December 2022, Trina Solar Australia, hadachieved revenue of more than one hundred million Australian dollars, being the threshold under
the Modern Slavery Act 2018 (Cth)Trina Solar continually endeavours to work with
its suppliers and stakeholders to raise awarenessof modern slavery and commits to effectively
communicate our expectations and, where appropriate, take any actions necessary to eradicate
modern slavery risks.

In line with the Act, Trina Solardefines “modern slavery” asincluding 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 2022 Modern Slavery Statement

01About Trina Solar (Australia) Pty Ltd
Trina Solar Australia is the Australian arm and wholly owned subsidiaryof Trina Solar Group, whose parent company, Trina Solar Co., Ltd.,was founded in 1997 (stock code: 688599.SH) with its headquarter
based in Changzhou City, Jiangsu Province, China. Trina Solar Groupis the world leading PV and smart energy total solutions provider.
Trina Solar Group is mainly engaged in:• the research and development, production andsales of PV modules, trackers and storage products;• PV power stations and system products;•PV power generation, operation and maintenance services; and• the development and sales of intelligent microgrids and multi-energy systems, as well as theoperation of energy cloud platforms, amongst
other things.
Trina Solar Group is committed to leading the way
in smart solar energy solutions for a net-zerofuture. Through constant innovation, Trina Solar
Group continues to push the PV industry forward
by creating greater grid parity of PV power and bypopularizing renewable energy. Trina Solar Grouphas been consistently ranked as the first tier PV
module manufacturer in the world. In addition,
Trina Solar Group’s downstream business includes
solar PV project development, financing, design,construction, operations and management, andone-stop system integration solutions for customers. Trina Solar Group has connected over
5.5GW of solar power plants to the grid worldwide.
As of May 2023, Trina Solar Australia has twenty-three (23) full time employees that range
from sales personnel to solar engineers, financeexperts and support staff. Globally, Trina Solar
Group has more than twenty-three thousand(23,000) employees, and has shipped 43.09GWof PV modules and 4.4GW of trackers throughout
the calendar year of 2022. Trina Solar Group nowsells PV products in more than one hundred (100)countries, with regional business centre in Singapore, Tokyo, Zurich, Dubai, Fremont and Miami,
global sales and office centres in Spain, Mexico,
Chile, Italy, Germany, Australia, United Arab Emirates, France, Columbia, Brazil and India, and production bases in Vietnam and Thailand.
Trina Solar Australia provides solar panels to EPC
project partners, constructors of solar farms andwholesalers. Its employees in Australia are allengaged through lawful labour contracts as per
local laws and are free to associate with theirrespective unions, as they may see fit.
Trina Solar Group is committed to corporate social
responsibility, including eliminating all forms ofmodern slavery, and to conducting business ethically and in compliance with all laws, rules, andregulations in the places/countries where it operates. This is implemented through our Code ofBusiness Conduct and Ethics, our Social Responsibility Management Regulation, Trina Solar Global
Human Rights Principles and various other guiding principles within our suppliers’ verificationand human resource management systems.
Trina Solar Group believes in being fully transparent with all partners and local authorities and willcontinue to refine its tools to address any and allmodern slavery risks.

Trina Solar (Australia) Pty Ltd 2022 Modern Slavery Statement

02

Trina Solar Supply Chain
Trina Solar’s supply chain covers more than eighty (80) types of procurement
products that are broadly spread into the following categories:

These are broadly spread into thecategories below:• raw materials;• auxiliary materials;• infrastructure;• equipment;• accessories;• packaging;• logistics;• transportation;• labour protection supplies;

producing the solar ingots by itself and it targets
to have sufficient production capacity startingfrom MG polysilicon in the near future.
To develop and identify potential suppliers, local
employment and labour rights are amongst themost important criteria for Trina Solar to eradicate
any modern slavery risks all throughout its global
supply chain as the above. All potential suppliers
are required to commit their compliance with alllocal labour laws as precondition to be approved
as the qualified vendor for Trina Solar Group.
More details will be introduced in later sections of
this statement as policies, measures, and actions
having been taken by Trina Solar.

• office supplies; and• third-party certification services.

Trina Solar‘s suppliers are mainly from China,German, Malaysia, Spain and Vietnam and arecentrally managed by Trina Solar Group’s procurement department in China.
Trina Solar Group now owns and operates several
manufacturing production bases respectively inChangzhou, Suqian, Yiwu, Yancheng in China, inVietnam and in Thailand. In the year of 2022, Trina
Solar has started construction of its Qinghai manufacturing facility with its investment amountbeing over RMB 50 billion, in Qinghai province,China, which will provide a full photovoltaic industry chain and take the lead in building a “zerocarbon industrial park integrating source, network, load, and storage” in Xining, Qinghai (hereinafter referred to as “Trina Qinghai Facility”).
Now, Trina Qinghai Facility has already begun

Trina Solar (Australia) Pty Ltd 2022 Modern Slavery Statement

03Modern Slavery Risk Management
Trina Solar Group and Trina Solar Australia have classified modern slavery
risks into external and internal categories. The external modern slavery
risks are managed by Trina Solar Group’s procurement team while any
intercompany risks are managed by the human resource and legal & compliance departments of Trina Solar Group and Trina Solar Australia together.

Areas of risks identified by Trina
Solar within its business operations
include:• raw material suppliers;• storage and logistical providers;• Trina Solar owned and OEM factories;• distributors;• installers;• EPC providers or developers for solarprojects;• research and development partners;• shareholders;• consumers (end-users); and• employees.

Supplier risks are managed through Trina Solar
Group’s internal procurement practices and the
supplier performance evaluation system. These
provide our suppliers with a score between one(1) to five (5) in relation to their corporate social
responsibility commitments and overall treatment of workers. As part of these systems andoverall evaluation, Trina Solar actively seeks
information from its suppliers such as theiremployee turnover ratio, any reported healthor ethics code breaches, and a number of otherkey metrics to ascertain the supplier’s level ofemployee satisfaction.
All information provided by suppliers is assessedagainst Trina Solar’s Code of Business Conduct
and Ethics and any failure to comply with theset criteria means either full remediation by
the supplier is immediately required or there isimmediate suspension of said supplier.
Internally, Trina Solar Group’s human resource
department periodically updates our employee
handbooks to reflect the employee’s rights atwork in accordance with all applicable laws.
Furthermore, we provide online courses to all
employees as well as an annual engagement
survey to gauge all employees’ sentiments on f
air treatment, health and safety, benefits,training and so on.

Trina Solar (Australia) Pty Ltd 2022 Modern Slavery Statement

04

Policies and Governance
The policies of Trina Solar Group associated with addressing modern slavery
risks are contained within the following documents:

Trina Solar Group strives toensure that their products
do not incorporate or containcomponents of materials thathave been produced, manufactured or provided using anyform of forced labour or slavery.
There is a well-established team
who are responsible for developing and monitoring compliancein relation to modern slavery, asfollows:

Trina Solar’s Code of BusinessConduct and Ethics(to be provided upon request);
Trina Solar’s Social Responsibility
Management Regulation(http://static.trinasolar.com/sites/default/
files/Trina%20Solar%20Social%20
Responsibility%20Management%20Regulation.pdf);
Trina Solar Global Human
Rights Principles• Internal audit;(http://static.trinasolar.com/sites/default/
files/TrinaSolar_Global_Human_Rights_Principles.pdf);• Global compliance;• Legal department;

2023 Reconfirmation of the ProductStewardship Policy• Human resources department;• Procurement department;(http://static.trinasolar.com/sites/default/files/Product_Stewardship_Policy_2023.
pdf).

• Quality Control; and• Brand Management.

Trina Solar Group issues its corporate socialresponsibility report based on a social responsibility assessment, annual inspections andevaluations conducted of all its suppliers (2022
Sustainability Report is accessible at http://static.trinasolar.com/sites/default/files/TrinaSolar_CSRreport_ESG_2022_EN.pdf ).
Trina Solar Group’s global procurement teammonitors Trina Solar Group’s global supply chain
partners to ensure that such partners avoid
any involvement whatsoever with forced labour
practices.
Trina Solar (Australia) Pty Ltd 2022 Modern Slavery Statement

05

Actions
In 2022, Trina Solar Group updated its Code of Business Conduct and Ethics,
with a strong emphasis on the protection of human rights and fair treatmentof all workers. All Trina Solar Group and Trina Solar Australia employees
have received the updated Code of Business Conduct and Ethics and wereprovided with compliance training in order to ensure awareness of the risks
of modern slavery and human trafficking. Trina Solar’s Code of BusinessConduct and Ethics, to which every employee must adhere, defines thecompany values and guiding principles, including a commitment to conductbusiness ethically as well as in compliance with all laws, rules and regulationsin the places/countries where doing business.
Labour and legal compliance clauses have always
been included as part of the standard supply and/or service agreements worldwide being appliedby Trina Solar Group and Trina Solar Australia.
Additionally, all Trina Solar Group and Trina Solar
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 Trina Solar’s Compliance Committee through a fully confidential andanonymous hotline, or via email to the report
email address: scc@trinasolar.com

they are approved as a Trina Solar Group’s qualified
supplier. Such letter includes a commitment to pay
salaries on time and in accordance with local laws
and regulations, as well as providing insurance
coverage to its employees, strictly abiding by theprovisions on working hours in the given jurisdiction and to not recruit workers that are underageor are viewed as forced labour.

.

Besides, Trina Solar Group sets up an IT traceability system for its customers named Phegda Big
Data System, which is continually being updated.
Such system can generate trace report of thematerial of particular shipment of solar modules
as required by the customer in advance. Now,
Trina Solar Group is updating such traceability
system as to include the solar products to be manufactured by Trina Qinghai Facility.
Finally, all new suppliers must sign and executea letter of commitment/undertaking confirming
the lawful employment of all their workers before

Trina Solar (Australia) Pty Ltd 2022 Modern Slavery Statement

06

Valuation of Effectiveness
Trina Solar acknowledges that it
may continue to encounter modern
slavery risks and its efforts tomitigate these risks will be an ongoing process. In order to accurately
assess and measure the effectiveness of Trina Solar’s actions, thecompany aims to provide updated
reports on the following:• Continued reviews of its key supplier
agreements to ensure provisions related
to modern slavery are included.
• Continued training provided to all
employees to increase awareness ofmodern slavery risks and subsequent
competence evaluations to verify theeffectiveness of such training.

Trina Solar’s sustainability efforts have been
audited since 2014 by EcoVadis, an independent
rating auditor, and one of the largest and mosttrusted providers of independent businesssustainability ratings worldwide. Trina Solar
Group has continuously been rewarded over theyears with outstanding records for protection of
the environment and of employee rights in corporate social responsibility performance surveys
conducted by EcoVadis (all such certificatesare accessible at https://www.trinasolar.com/en-glb/our-company/sustainability-downloads).
Trina Solar is also certified with ISO45001
Occupational Health and Safety ManagementSystems.

• Regular reviews and ongoing monitoringof supplier’s responses to Trina Solar
Group’s supplier KYC questionnaire.
• Self-reporting from Trina Solar Group andTrina Solar Australia’s external partners
on any identified or suspected modern
slavery issue.

Trina Solar (Australia) Pty Ltd 2022 Modern Slavery Statement

07Continuous Improvement
Trina Solar acknowledges that, as part of its commitment to implement
zero tolerance towards modern slavery within its ecosystem and businesson a day-to-day basis, it is necessary to continuously review its risk management system and make improvements where and when necessary.

Trina Solar Group and Trina Solar Australia have identified some key areas foradditional focus, and for future development, including:• continued engagement with employees,
external partners and service providers on
all topics related to modern slavery risks
to ensure full satisfaction with Trina SolarGroup expectations and those of all local
jurisdictions;• examining industry codes of conduct andhow these may apply to Trina Solar Group andTrina Solar’s practices in an improved way on atimely basis;• investigation of any options for theautomation and streamlining of Trina Solar
Group and Trina Solar’s suppliers throughthird-party solutions; and• continued measuring of Trina Solar Groupand Trina Solar’s progress and performance,
both internally and externally.

We remain at your disposal should you
have any queries on the above.
Date Signed:

Ding Ying
Director

Jiang Yanhong
DirectorTrina Solar (Australia) Pty Ltd 2022 Modern Slavery Statement

08

General enquiries
Tel: +61 1300 874 627 Fax: +61 2 9199 8006
(Monday to Friday 9:00am to 4:30pm)
3 Banfield Road
Macquarie Park NSW 2113
ABN: 24 150 695 524

www.trinasolar.com/au