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OPENAX companies including all subsidiaries, holdings, and affiliated entities (“OPENAX”) work with many suppliers worldwide to fulfill client engagements. In this context, OPENAX holds that corporate social responsibility should extend to its entire supply chain. This Supplier Code of Conduct (“Code”) outlines the standards and business practices to which OPENAX requires its direct and extended Suppliers to adhere in the course of their dealings and conduct with OPENAX, its employees and on its premises. The scope of this requirement includes all tiers of suppliers, manufacturers, contractors, subcontractors, agents, distributors, and consultants (each a “Supplier” and collectively “Suppliers”). It also extends to parent, subsidiary, agents, subcontractors, and affiliate entities and applies to all workers, including permanent, temporary, contract, foreign, or migrant workers (each an “Worker” and collectively “Workers”). It is the Supplier’s responsibility to ensure compliance with both the intent of this Code among all Workers and throughout its supply chain, including all sub-tier suppliers/individuals, through dissemination, education, and verification.
OPENAX reserves the right to modify the provisions in this Code as it deems fit, but in particular due to changes related to its compliance program, changes on applicable legislations, rules or regulations. In such case, Recom Technologies notify its Supplier in writing and may provide training on respective changes if necessary. The Supplier will be bound by such modifications upon delivery of notice without the need for Supplier’s consent or acknowledgment.
Legal Compliance: The Supplier will uphold legal and regulatory standards in every aspect of business, and comply with the laws, policies and standards that guide activities around the world, including Code of Ethics and Business Conduct of OPENAX CODE OF ETHICS AND BUSINESS CONDUCT. Suppliers shall: - Comply with all applicable laws and regulations of the countries, states, and localities in which they operate. This includes, but is not limited to, laws and regulations related to ethical business practices, antitrust or competition law, quality, labor and employment practices, health and safety, environmental protection, data privacy and protection, and economic sanctions (including embargoes), and any other laws that are otherwise applicable to the products and/or services provided to OPENAX. - Abide by industry standards of conduct relevant to the areas described in this Code. - Obtain, maintain, and operate in accordance with all applicable permits, licenses, and registrations.
Anti-corruption: The Supplier will comply with the provisions of all applicable anti-bribery and anticorruption laws, rules and regulations in countries where the Supplier conducts its business, and shall comply with the Anti-Bribery and Anti-Corruption Policy of OPENAX as described in its Code of Ethics and Business Conduct. Suppliers will not pay bribes or engage in corrupt practices in order to advance business interests of OPENAX. This includes any direct or indirect offering, promising to pay or authorizing the payment of money or anything of value to local government officials for the purpose of influencing the decision of public officials.
Fair Competition: Suppliers must not engage in illegal cooperation with competitors including bid rigging, price fixing, market allocations, or any other prohibited conduct that limits free and fair competition.
Confidential Information: Suppliers must secure OPENAX is private and confidential information in their possession, use it only per our instructions, and safeguard it from unapproved or unintended disclosure. Suppliers and Workers are prohibited from taking photos or video while on OPENAX premises without preapproval. This obligation continues after our business relationship ends.
Non-retaliation: The Supplier will support an open environment where individuals feel comfortable asking questions and reporting concerns. In this context, Suppliers shall have a system in place to empower workers to report concerns or grievances in the workplace, free from fear or threat of reprisal, retaliation, intimidation, and harassment.
Conflicts of Interest: The Supplier will take appropriate measures to prevent conflicts of interest and make business decisions based on the interest of the Supplier’s company and not for personal gain or benefit. Suppliers shall:
Export, Import and Trade Controls: The Suppliers shall abide by all relevant applicable laws and regulations on trade, import and export controls in the countries/regions where they operate, and earnestly fulfill relevant responsibilities and obligations.
Suppliers must respect their Workers by ensuring them, within the context of the Supplier’s business operations, a right to life, personal liberty, and personal security. Suppliers must comply with all applicable laws and regulations, including treaties and international standards such as the UN Global Compact’s Ten Principles, UN Guiding Principles, Universal Declaration of Human Rights, International Bill of Human Rights, OECD Guidelines for Multinational Enterprises, and the ILO’s Core Labour Standards as codified in the 8 core conventions. Special attention to ensuring these rights are upheld should be given to those who are at heightened risk for vulnerability or marginalization such as women, young people, indigenous peoples, ethnic/racial minorities, people with disabilities, and migrant or foreign workers.
Non discrimination: Suppliers will not discriminate in hiring, compensation, discipline, termination or retirement, relying on a person’s race, color, gender, national origin (or ethnicity), age, religion, disability, sexual orientation, gender identity, veteran status, marital status and any other protected characteristics or beliefs.
Harassment: Suppliers will not subject their employees to physical, verbal, sexual, or psychological harassment, nor use corporal or physical punishment to discipline employees.
Coercion: Suppliers shall not use any means of coercion such as intimidation, threats, or harassment, directly or indirectly, to pressure Workers into accepting or staying in a job. All Workers are to freely choose their employment and must be aware of all terms and conditions associated with their employment status, job functions, compensation, and process for termination of employment by either the Supplier or Worker. The Supplier must provide this information to the Worker in their primary language and all contractual elements are to be agreed upon before the commencement of employment activities. Records of all Worker contracts and agreements should be kept and be available for review or verification purposes by Recom Technologies or an appointed third party.
Compensation: Suppliers will comply with applicable compensation laws and regulations, including those relating to minimum wages, overtime premiums, allowances and benefits. Suppliers shall pay at least the legally required compensation or the prevailing industry compensation, whichever is higher.
Working Hours: Suppliers will comply with all applicable laws and regulations regarding working hours. Other than in exceptional circumstances, workers must not work over the legal limits or over regular overtime hours per week. Overtime shall not be requested on a regular basis and must be voluntary.
Work Documentation: Suppliers must only employ Workers with legal authorization to work in accordance with all local laws and regulations. Authorization must be validated through appropriate legal documentation. Suppliers shall not confiscate, or in any way withhold, legal documentation of Workers.
Freedom of Association and Right to Collective Bargaining: OPENAX recognizes the right of Workers to form employee representative bodies and to bargain collectively to regulate working conditions. In its operations, the Supplier shall uphold the right of employees to join trade unions. Establishing, joining, or becoming a member of a trade union shall not be used as a reason for unjustified 3 discrimination or retaliation. Unions shall be allowed to operate freely and in accordance with the law of the place of employment. This includes the right to strike and the right to collective bargaining. The supplier shall exclude the use of security forces to interfere with freedom of association. OPENAX encourages suppliers to promote constructive and transparent dialog between employees, their representatives, and management when handling internal conflicts and grievances relating to working conditions.
Suppliers will not employ individuals in violation of the local mandatory school age or under the legal employment age in the country where they operate. Moreover, in no case will Suppliers employ workers under age 15, except for child actors and models employed in advertising or media who are protected by applicable child labor requirements.
Suppliers will employ all employees under their own free will with no one being subjected to bonded or forced labor. This policy applies to not only the supplier’s business operations but also those of their supplier network with which the company conducts its business. Suppliers are prohibited to procure raw material from banned areas and entitles that are in sanction lists. In particular, Suppliers are obliged to conduct extensive due diligence to ensure that none of the components or materials comprising its products originate from the following suppliers: 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), and none from their suppliers in the upstream level is included in the UFLPA Entity List, as mentioned in the following link: https://www.dhs.gov/uflpa-entity-list. OPENAX does not tolerate any form of Forced Labor and requires its Suppliers to comply with all applicable international laws and regulations. These laws include but are not limited to the following:
The protection and promotion of the health of its workers is a top priority for OPENAX. The Supplier shall comply with all national and international standards and laws on occupational safety (in particular safety at work, health protection, working hours) that apply to its location of business. Upon request of Recom Technologies, the Supplier shall
OPENAX believes in doing business with suppliers who share our commitment to protecting the quality of the environment around the world through sound environmental management. Suppliers will comply with all applicable environmental laws and regulations and will promptly develop and implement plans or programs to correct any non-compliant practices. OPENAX requires that the supplier shall also make continuous efforts to reduce their environmental pollution and risks and improve environmental protection within their own sphere of influence on an ongoing basis. The use of resources (in particular energy, water, raw materials and/or (primary) materials) and the environmental impacts (in particular emissions, pollutants, waste) are to be consistently minimized. Suppliers shall seek to reduce waste and adopt responsible measures to minimize and mitigate the environmental impact of their operations.
Water and Waste: The Supplier must embrace the responsible management and stewardship of water and waste and take proactive steps to assess and address pharmaceuticals and personal care products in the environment. Suppliers shall:
Plastics and Packaging: The Supplier must take steps to reduce dependency on single-use plastics and prioritize the improvement of the environmental profile of packaging materials. Suppliers shall, where relevant to their business:
Raw Materials and Conflict Minerals: The Supplier will uphold human rights standards and environmental standards related to materials across the supply chain, work to detect and eliminate conflict mineral sources and to understand and reduce environmental harm or degradation, including in relation to materials that may contribute to deforestation or human rights abuses. ‘Conflict minerals’ refer to metallic minerals, such as tin, tantalum, tungsten, gold and cobalt that were exploited, this produces serious problems regarding human and environmental rights during exploit and sales. Suppliers shall, where relevant to their business:
Climate Action: The Supplier will operate in an environmentally responsible manner to reduce greenhouse gas emissions. Suppliers shall:
Decarbonization: OPENAX is committed to the Paris Agreement (COP 21) and has set a CO2 reduction target throughout its entire product life cycle. As part of the nomination process, the Supplier undertakes to implement measures to reduce its direct and indirect CO2e emissions (including in its 5 upstream value chain).
This includes, for example, the use of green electricity and the use of secondary materials or biomaterials. Compliance with the requirements concerning CO2e emissions reduction is a decisive criterion for OPENAX in the process of selecting its Suppliers. OPENAX expect Suppliers to ensure transparency with regard to their own emissions as well as those of the upstream supply chains (e.g. by using life cycle assessments (LCA)), and to set reduction targets, including targets that apply to their supply chain.
The Suppliers shall ensure that they and their suppliers/partners are in compliance with local laws and regulations on labor protection and environmental protection as well as relevant international treaties, and shall take appropiate steps to prevent, mitigate, terminate or minimize adverse implications on labor protection and the environment through internal rules and regulations. The Supplier shall take all reasonable precautions to ensure that Supplier and each of its vendors or subcontractors complies with requirements consistent with this Code and fulfills the minimum criteria, as listed below;
For OPENAX, the commitment of its Suppliers to meet their social and environmental responsibilities is an indispensable prerequisite for any business relationship. It is therefore expected that the Supplier has established or is implementing a due diligence process with appropriate measures to ensure that its suppliers and subcontractors, in turn, also comply with the standards and rules set out in this document, and takes as minimum the follwing actions:
Risk management: The supplier is expected to implement an appropriate and effective management system for corporate due diligence toward people and the environment in its organization as well as with its direct suppliers. This includes but is not limited to contractual agreements, a supplier policy for sustainable procurement, and audits. The Supplier shall pass on sustainability requirements in accordance with this Supplier Code of Conduct to its suppliers.
Notification and remedy mechanisms: If the Supplier becomes aware that requirements from the Supplier Code of Conduct have been violated in its own business area or in its supply chain, it shall immediately take appropriate remedial action. In case of confirmed violations, the Supplier shall inform OPENAX ([email protected]) immediately of any violation of the obligations arising from this Standard in its own business area or in its supply chain, or of any official investigation procedure in this regard.
OPENAX meets due diligence obligations in the supplier network based on international standards and laws. We review and implement compliance with the expectations and requirements defined in this Supplier Code of Conduct as follows:
Audit and Information Rights. On an ad hoc basis, OPENAX requires collaboration with suppliers and sub-suppliers with the target of achieving traceability and maximum transparency in relevant high-risk supply chains, to the source of origin if needed. Upon request, the Supplier shall fully and truthfully answer questions from OPENAX about compliance with its obligations under 6 this Standard, including its actions, any violations, and grievances.
The Supplier shall also provide relevant documentation upon request and nominate contacts for inqueries. In order to review suppliers’ compliance with the standards set out in this document, OPENAX uses for example, standardized self-assessment questionnaires with requirements relating to nomination, as well as third-party audits, and on-site inspections by sustainability experts appointed by OPENAX.
The selfassessment questionnaires and the audits cover broader content than that specified in this Supplier Code of Conduct. The Supplier shall cooperate to the best of its abilities in responding with honesty to the self-assessment questionnaire and with the audits. Recom Technologies may request further suitable certificates as Supplier verification. Recom Technolgies reserves the right to carry out risk analyses along the supplier’s entire supply chain. This may take the form of audits, for example, by independent third parties appointed by Recom Technologies or internal assessors.
Reporting Channels. In case of (potential) violations of the above-mentioned requirements, Recom Technolgies has implemented a grievance mechanism, which is available by e-mail at [email protected]
Handling of Violations. In the event of non-compliance with the mandatory requirements described in this Supplier Code of Conduct, OPENAX reserves the right to terminate business relationships, provided that no other effective means are available, and further increasing of influence is impossible.
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On December 23, 2021, the President of the United States enacted the Uyghur Forced Labor Prevention Act (UFLPA). This legislation enforces a ban on the importation of goods originating from the Xinjiang Uyghur Autonomous Region in China, under the presumption that products from the region are linked to forced labor.
The law establishes a rebuttable presumption that any item partially or entirely manufactured, mined, or produced in Xinjiang—or by entities named in the UFLPA Entity List—is not permitted to enter the U.S. market under 19 U.S.C. 1307. These goods are presumed to violate U.S. Customs regulations and are therefore subject to exclusion unless clear evidence proves otherwise.
OPENAX confirms that none of its products, including those manufactured or supplied through its subsidiaries, affiliates, or parent entities, contain materials sourced from the Xinjiang Uyghur Autonomous Region of China.
As part of our standard due diligence process, OPENAX takes thorough measures to ensure that no part of its solar panel components originates from any of the following entities:
We further ensure that none of our suppliers appear on the UFLPA Entity List.
OPENAX affirms that it neither directly nor indirectly utilizes forced labor in the production of its goods or sourcing of materials. All products and components provided by OPENAX comply fully with the standards outlined in the Uyghur Forced Labor Prevention Act and are eligible for lawful import into U.S. ports.
No part of our products is derived from or processed using silica-based materials linked to entities under sanction, including but not limited to Hoshine Silicon Industry Co. Ltd.
OPENAX maintains a strict stance against forced labor and continuously evaluates its supply chain partners to ensure adherence to responsible labor practices. This commitment extends to ensuring respect for human rights, labor regulations, ethical sourcing, and environmental sustainability across all procurement and business operations.
Information shared by OPENAX on its website or through other communications regarding product compliance with the UFLPA is based on our best knowledge at the time it is published. Our insights are informed by supplier disclosures, inspections when feasible, and available testing results.
While we strive to maintain accurate and up-to-date disclosures, OPENAX makes no guarantees regarding the absolute completeness or accuracy of third-party data. However, the company continues to make reasonable efforts to ensure transparency and integrity in its reporting practices.
OPENAX
Last updated: February 2025
OPENAX, including all of its subsidiaries, holdings, and affiliated entities, is fully committed to maintaining a respectful, inclusive, and equitable workplace. We aim to foster a culture in which diversity is recognized as a strength and all individuals are treated with fairness and dignity.
This policy has been established to:
This policy applies to:
OPENAX values a diverse workforce and encourages inclusion at every level. We strive to ensure that our employment practices are free from bias or prejudice, and all employment decisions are made based on merit, capability, and business need.
Discrimination on any protected ground is strictly prohibited. This includes, but is not limited to: race, ethnicity, religion, gender, sexual orientation, gender identity, disability, age, nationality, marital status, veteran status, pregnancy, or genetic information. Reasonable accommodations are provided for individuals with disabilities.
No employee or candidate shall be subject to medical testing—including pregnancy or virginity tests—or physical assessments that could result in discriminatory treatment. This policy reflects the principles of ILO Convention No. 111 on Discrimination in Employment and Occupation.
Any employee found violating this policy may face disciplinary action, up to and including dismissal. Employees should also understand that legal consequences may apply to acts of harassment, discrimination, or victimization in the workplace.
While personal circumstances and professional record may be considered, they will not override the company’s commitment to enforcing this policy. Contractors found in breach may be subject to termination of their contracts. Likewise, OPENAX expects suppliers to align with our standards; failure to do so may result in the end of the business relationship.
We take all complaints of discrimination and harassment seriously. Any concerns raised by employees, clients, contractors, or other third parties will be investigated in line with our grievance procedures. Those who submit complaints will be informed of the outcome.
Reports of misconduct can be submitted via email at [email protected]. Employees can also use internal feedback mechanisms through HR or management channels. All complaints are reviewed thoroughly, and appropriate actions are taken when violations are found.
OPENAX
Last reviewed: December 2024
OPENAX, including its group entities, affiliates, and subsidiaries, is committed to providing a respectful and equitable working environment grounded in fairness and dignity for all. As part of this commitment, OPENAX strongly opposes any form of child labour across its global operations and facilities.
The company does not employ individuals who have not reached the minimum legal age to complete compulsory education, as established by relevant national authorities. In addition, OPENAX complies fully with all applicable laws regarding working conditions, remuneration, hours, and overtime for young workers, where legally permissible.
According to the International Labour Organization (ILO), child labour includes any of the following:
Responsibility for enforcing this policy lies with the Human Resources and Security departments, who are instructed to prevent underage individuals from being employed. Employment records, including proof of age, are securely documented and remain accessible for review by authorized inspectors or legal authorities.
OPENAX requires its suppliers and external partners to uphold the principles of the UN Convention on the Rights of the Child and comply with all applicable international and domestic child labour laws. Suppliers must implement appropriate safeguards to prevent the use of child labour within their facilities and subcontractors’ operations.
OPENAX promotes awareness of the causes and consequences of child labour at all of its sites. Employees are regularly informed about the company’s zero-tolerance stance. For suppliers—particularly those operating in remote or high-risk regions—OPENAX provides clear guidance through its Supplier Code of Conduct, which forms a binding part of contractual agreements.
All staff are encouraged to report suspected breaches of this policy. Reporting is considered a moral obligation, and no employee will face retaliation for doing so in good faith.
It is the duty of local managers and HR teams to ensure adherence to this policy across all OPENAX operations. Additionally, OPENAX reserves the right to perform unannounced inspections at any site involved in the production of goods for the company, including those of subcontractors.
We also retain the option to appoint independent third-party auditors, at our discretion, to evaluate compliance with our child labour policy and identify areas for improvement.
Any breach of this policy may result in appropriate disciplinary or contractual action, including dismissal or termination of partnership. OPENAX commits to acting swiftly and decisively to address any identified violations related to child labour.
Our grievance mechanism forms an integral part of OPENAX’s human rights strategy. It allows stakeholders—whether employees, suppliers, or intermediaries—to report concerns in a confidential, secure, and accessible way.
Reports can be submitted in any language via email at [email protected]. Complaints are handled independently, with impartiality, and without external influence. Confidentiality is respected throughout the investigation process to protect whistleblowers and uphold integrity.
OPENAX
Last reviewed: December 2024
This policy outlines OPENAX’s firm commitment—across all subsidiaries, affiliates, and group entities—to uphold essential labor standards across all operations, in accordance with internationally accepted human rights principles.
These standards are built on the foundation of the UN Universal Declaration of Human Rights, aiming to ensure ethical labor practices throughout OPENAX’s business activities.
OPENAX prohibits the use of any form of forced, bonded, or involuntary prison labor. Employees are not required to deposit personal documents or funds as a condition of employment and may resign in accordance with the terms outlined in their contracts.
We respect every employee’s right to join, or not to join, organizations of their choice for collective bargaining, as allowed by local laws. OPENAX upholds workers' rights to freedom of association without interference.
In line with ILO standards, OPENAX does not employ individuals below the legal working age in any jurisdiction. No employee under the age of 15 may be engaged under any circumstances, including through suppliers or partners.
OPENAX complies with all local laws and collective agreements governing working hours, rest breaks, and public holidays. The standard workweek is limited to 40 hours (excluding overtime), and overtime remains voluntary. A rest day is provided for every seven-day period, and total overtime will not exceed 12 hours weekly unless exceptional short-term needs arise.
Employees at OPENAX receive fair compensation in accordance with applicable minimum wage legislation or prevailing industry benchmarks. Overtime is paid at premium rates as legally defined. No unauthorized deductions are made, and wages are paid transparently and on time, with all benefits clearly itemized.
OPENAX is committed to:
OPENAX guarantees that employee data is handled responsibly, lawfully, and transparently. We only collect personal data required for specific, legitimate purposes and maintain security through technical, administrative, and organizational safeguards.
Key principles include:
OPENAX does not tolerate any form of discrimination in employment decisions, including recruitment, compensation, promotion, or termination. We promote equal treatment regardless of race, gender, religion, disability, age, marital status, nationality, sexual orientation, political views, union affiliation, or any other status.
We are committed to providing a safe and healthy work environment. Risks are minimized through preventative measures and continuous improvement of safety practices. Employees receive appropriate safety training, and clean facilities, drinking water, and, where applicable, food storage options are made available. A senior manager oversees health and safety compliance.
Our approach to labor and human rights is embedded into company governance, strategy, and operational systems. Suppliers and business partners are expected to align with these commitments. Non-compliance may result in corrective measures or termination of contracts and partnerships.
OPENAX promotes respectful and fair workplace relationships. Employees have multiple channels to report concerns, including directly to HR or management. We involve stakeholders where necessary and take corrective action when needed.
We operate under a zero-retaliation policy. Any employee raising concerns in good faith is protected from any form of reprisal. Complaints related to disrespectful behavior, safety, or labor violations are taken seriously and acted upon swiftly.
OPENAX
Last reviewed: December 2024
OPENAX, including all of its holdings, subsidiaries, and affiliated entities, upholds and respects globally recognized human rights. Our principles are guided by international frameworks such as the United Nations Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, the International Covenant on Economic, Social and Cultural Rights, ILO Core Conventions, the Voluntary Principles on Security and Human Rights, and, where relevant, international humanitarian law.
OPENAX is dedicated to avoiding, preventing, and addressing any negative impacts on human rights within our sphere of influence. This applies to our employees, contractors, supply chain workers, local communities, and others potentially affected by our operations. We actively implement processes to mitigate risks and ensure we do not contribute to human rights violations.
To support and protect human rights throughout our operations, OPENAX commits to the following actions:
OPENAX is committed to transparency and encourages employees and partners to voice concerns without fear of retaliation. We promote a “speak-up” culture, and all reports of misconduct—ethical, legal, or otherwise—are taken seriously and investigated thoroughly.
We do not tolerate retaliation against anyone who raises a concern in good faith or contributes to an investigation. Employees, partners, and third parties are welcome to report concerns or suspected violations related to human rights.
Reports can be submitted by email to [email protected]. All cases are reviewed, and where violations are confirmed, we take appropriate action and provide effective remedy.
In addition, OPENAX has procedures in place to address issues specifically related to sourcing of raw materials. We uphold a strict non-retaliation policy for those who raise legitimate concerns and firmly oppose any attacks against human rights defenders.
OPENAX
Last reviewed: December 2024
OPENAX operates in line with all applicable health and safety standards and actively seeks to enhance its safety policies and procedures. With a large portion of staff working in manufacturing environments, safety is a top priority. We take preventive action to minimize hazards, avoid incidents, and encourage safe conduct throughout our operations.
Access to healthcare services differs widely depending on the country of operation, especially in developing regions. Where gaps are identified, OPENAX implements solutions to ensure employees and their families receive adequate healthcare support at the local level.
To support mental health—addressing stress, sleep issues, and work-life balance—OPENAX provides resources such as digital wellness content and encourages employees to take active breaks. With hybrid work now established, we’ve introduced flexible working policies globally, along with initiatives promoting mindfulness and healthier work habits for remote staff.
OPENAX adopts a strategic and layered approach to accident prevention, covering technical, organizational, and personal safety aspects.
Potential emergencies are proactively identified and assessed. OPENAX develops response plans that include notification protocols, evacuation routes, training sessions, and simulation drills to ensure readiness in crisis situations.
Despite thorough prevention efforts, accidents can still occur. Names and contact information of trained first responders and volunteer rescue personnel are posted at first aid stations. These individuals receive ongoing refresher training.
All workplace incidents must be reported promptly—no later than the next working day—to the immediate supervisor. The report must include accident details, impact, cause, and corrective actions to prevent recurrence. This is especially crucial for incidents resulting in employee or third-party inability to work.
Each reported case is reviewed by the designated safety expert, together with occupational health professionals and relevant site managers. Investigations aim to identify root causes and implement effective preventative measures.
OPENAX
Last reviewed: December 2024
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:
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:
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
The Modern Slavery Act (the “Act”) took effect on October 29, 2015. It addresses serious human rights violations, including slavery, forced labor, and trafficking in persons, where individuals are exploited and denied freedom for profit or personal advantage. The Act aims to eradicate such practices and requires organizations to identify and mitigate the risk of modern slavery in their operations and supply chains. It consolidates legal provisions around crimes related to forced labor, trafficking, and other exploitative conduct.
OPENAX is an international renewable energy company active across the solar industry. Its core activities include the manufacturing of modules, cells, inverters, hybrid energy storage systems, batteries, and EV charging solutions. OPENAX collaborates closely with leading research institutions and industrial partners to bring innovative technologies to market.
OPENAX, along with its affiliated, parent, and subsidiary entities (“OPENAX”), is fully aligned with the principles outlined in the Modern Slavery Act 2015. We maintain a strict zero-tolerance stance on any form of forced labor or human trafficking. We take deliberate steps to reduce the likelihood of contributing to such violations, both within our business operations and throughout our supply chains. We acknowledge that these risks can arise at various points—from sourcing raw materials to hiring subcontracted labor.
As part of our ongoing risk management efforts, OPENAX is implementing systems that allow us to:
We expect our suppliers to comply fully with all applicable national and international laws. Workers must be treated ethically and with respect. Our contractual agreements with suppliers include provisions requiring them—and their own suppliers—to adhere to OPENAX’s Supplier Code of Conduct. These terms specifically prohibit the use of forced or bonded labor, human trafficking, and similar practices.
OPENAX conducts regular training sessions and provides guidance to procurement teams and decision-makers to reinforce compliance with anti-slavery standards. Employees are trained to recognize indicators of modern slavery and are encouraged to report violations or suspicions immediately.
Our procurement department performs supply chain mapping to evaluate geographic and product-related risks, ensuring that none of our materials originate from banned entities such as:
We further ensure that no suppliers on the UFLPA Entity List are part of our upstream supply chain.
In addition, OPENAX supports its suppliers by offering strategic advice to help them build stronger, more sustainable practices within their own operations.
OPENAX may conduct audits of selected suppliers to verify adherence to our Supplier Code of Conduct. These audits, which may be announced or unannounced, include on-site inspections and follow the frequency defined by the applicable audit standards. Where violations are found—whether legal breaches or unethical labor practices—we reserve the right to end the business relationship.
We promote a culture of openness and integrity. OPENAX protects all individuals who raise concerns under this policy in good faith, regardless of whether the concern is ultimately substantiated. Any act of retaliation will lead to disciplinary action as outlined in our Code of Conduct and Business Ethics.
OPENAX
Last reviewed: December 2024
