Force labour and human trafficking prevention

Forced Labour and Human Trafficking Policy – OPENAX Forced labour refers to any work or service that an individual is compelled to perform against their will, under threat, coercion, or penalty. It includes situations where individuals are not acting of their own volition. Our Position OPENAX firmly opposes any form of forced labour or modern… Continue reading Force labour and human trafficking prevention

Forced labour refers to any work or service that an individual is compelled to perform against their will, under threat, coercion, or penalty. It includes situations where individuals are not acting of their own volition.

OPENAX firmly opposes any form of forced labour or modern slavery, including human trafficking. This includes labor performed under coercion, threat, or disadvantage, such as debt bondage or involuntary prison labour. OPENAX prohibits all types of forced labor, including indentured, bonded, slave or prison labor, as well as human trafficking in any form.

We are committed to building ethical supply chains by ensuring that no worker pays fees to secure employment, that they retain possession of their identification or travel documents, and that they are free to move without restriction. At OPENAX, workers receive clear and understandable terms of employment before departing their country of origin.

All suppliers must hire workers on a voluntary basis and under lawful conditions. These obligations extend not only to direct operations but also throughout the supplier’s subcontracting and sourcing chains. Suppliers are strictly forbidden from sourcing raw materials from sanctioned regions or banned entities.

Suppliers must perform robust due diligence to ensure that no raw materials or components used in their products originate from the following organizations:

• Hoshine Silicon Industry (Shanshan) Co., Ltd
• Xinjiang Daqo New Energy Co., Ltd
• Xinjiang East Hope Nonferrous Metals Co., Ltd
• Xinjiang GCL New Energy Material Technology Co., Ltd
• Xinjiang Production and Construction Corps (XPCC)

They must also ensure that none of their upstream suppliers appear on the UFLPA Entity List.

OPENAX requires full compliance with all relevant international laws and frameworks, including but not limited to:

• United States Uyghur Forced Labor Prevention Act (UFLPA)
• United States UFLPA Entity List
• The California Transparency in Supply Chains Act
• The United Kingdom Modern Slavery Act 2015
• Germany's Lieferkettengesetz / Supply Chain Act
• Norway’s Transparency Act (Åpenhetsloven)
• France’s Duty of Vigilance Law
• Australia’s Modern Slavery Act 2018

The OPENAX Code of Ethics and Business Conduct is accessible at all times to employees via the company intranet and to external parties through the website. It is regularly promoted through internal communications and training events.

All employees, regardless of role or seniority, are required to complete mandatory training on the Code. Senior managers are also required to confirm their understanding and compliance on an annual basis, based on identified risk areas.

OPENAX has also developed a Supplier Code of Conduct, which sets out clear expectations regarding the business behavior of suppliers and partners. This includes respect for human rights, the prohibition of forced or child labor, adherence to environmental standards, and anti-corruption measures.

Additional product-specific requirements are included within technical specifications that suppliers must comply with. These are binding and critical for continuing any business relationship.

Any breach of this policy may result in disciplinary measures, including but not limited to dismissal or contract termination. OPENAX will act swiftly and effectively to identify and eliminate any cases of forced labour or trafficking.

OPENAX has established a formal complaints procedure to detect and address human rights concerns at an early stage. Anyone — including employees, suppliers, customers, and third parties — can report suspected violations or misconduct.

Reports may be submitted at any time, 24/7, 365 days a year. They are accepted by email and can be written in any language. Reports should be sent to: [email protected].

OPENAX
Last reviewed: December 2024