ContentsSolar Commitment Handbook – Founding YearContents

Item Page1. Introduction 2

2. Definition of Terms 3

3. About SEIA 4

4. About the Solar Commitment 5

5. Commitment Requirements for Participation 6

6. Timeline for ParticipantSolar Participant Implementation 7

7. Governance of the Commitment 8

8. Communicating about the Solar Commitment 9

9. Tracking company progress: Corporate reporting 9

10. Membership fees and payment 10

11. Role of Audits in the Solar Commitment 10

12. Grievance Policy 10

13. Reviewing the Solar Commitment Program 10

Appendix

1. The Solar Commitment 12

2. FAQs about the Solar Commitment 20

3. Template/Example Letter of Intention to Participate 23

4. Advisory Committee Terms of Reference 24

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Introduction

Welcome. This handbook covers everything you need to know to get the started on the SEIA Solar Industry Commitment to Environmental & Social Responsibility (Solar Commitment) as a Participant Solar Participant of the Solar Commitment program. The handbook will help you understand the importance of the Solar Commitment and what your roles and responsibilities are as a ParticipantSolar Participant.

The handbook is divided into the following sections:

1. About the Solar Energy Industries Association (SEIA) – This section provides general information about our organization.

2. About the Solar Commitment – This section provides information about the Commitment itself.

3. Commitment Requirements – This section will help you get started in your Commitment Requirements as a Participant Solar Participant.

4. Timeline of Implementation – The Solar Commitment is in its first year of its programmatic roll-out. We are providing requirements for ParticipantSolar Participants that enter the program the first year.

5. Governance of the Commitment – This section has a general outline of how decisions are made for the Commitment.

6. Communicating about the Solar Commitment – This section gives guidance on how SEIA and Solar ParticipantSolar Participants can communicate about their participation in the Solar Commitment.

7. Tracking Progress – This section outlines our transparency requirements.

8. Membership Fees and Payment – Currently, there is no fee to participate in the Solar Commitment efforts

9. Role of Audits – This section outlines the role of audits in the Solar Commitment.

10. Handling Grievances – This section describes the policy and process SEIA will undertake if a third party brings attention to a non-conformance issue of a Solar Participating entity.Solar Participant.

11. Reviewing the Solar Commitment Program – This section outlines when and how often the Solar Commitment will be reviewed and by what process.

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Definition of TermsContinuous Improvement means that an entity has an ongoing effort to evaluate and improve their and their suppliers’ implementation and conformance to the Solar Commitment.

EHS Committee is the Environmental, Health, & Safety Committee of SEIA. This groupe Committee is responsible forconsists of four subgroups: Environmental & Social Responsibility Working Group, Codes & Standards Working Group, PV Recycling Working Group, and the Installer Safety & Workforce Development Working Group. …As a whole, the Committee and subgroups address all sustainability, environmental, and health topics of the solar industry.

Participant: see “Solar Participant”

Key Performance Indicators (KPI): a set of specific and material metrics that the EHS Committee of SEIA and the Solar Commitment Advisory Group develop and agree upon. As part of the Solar Commitment, Solar Participants will report their progress in each KPI. for Solar Participant annual reporting against.

KPIs: see “Key Performance Indicators”

Solar Participant is an entity in the solar industry that has indicated their interest in participating in the Solar Commitment, and has agreed to the ParticipantSolar Participant requirements and has been acknowledged as a participantSolar Participant by SEIA into the Solar Commitment program.

Good faith effort means that participantSolar Participants must show a good faith commitment towards the agreement Solar Commitment, and implementation of the Solar Commitment, and the KPIs and tools that supports its success.

Solar Commitment Advisory Group (Advisory Group) is a group of external stakeholders organized to advise the SEIA EHS Committee on implementation of the Solar Commitment, specifically the development of KPIs.

Founding Year is the first-year of the Solar Commitment (2012), in which the KPIs and other supporting tools will be developed.

First-tier suppliers are considered to be suppliers who Solar Participant company manages directly and who provide products or services that are key to the Solar Participant’s solar business.

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About SEIA- Mission- What We Do

Established in 1974, the Solar Energy Industries Association (SEIA) is the national trade association of the U.S. solar energy industry. Through advocacy and education, SEIA is working to build a strong solar industry to power America. As the voice of the industry, SEIA works with its 1,100 member companies to make solar a mainstream and significant energy source by expanding markets, removing market barriers, strengthening the industry and educating the public on the benefits of solar energy. SEIA is a 501 c (6) non-profit association. A separate 501 c(3) called The Solar Foundation oversees policy-driven research and develops education outreach programs to promote positive policy and further deployment of solar energy in the U.S.

SEIA is working to help meet the solar industry's goal of installing enough solar to power 2 million American homes each and every year by 2015:

Advocating for market-based policy at the federal level Providing the most comprehensive solar market research including the quarterly Solar Market

Insight report Offering SEIA members a wide range of benefits not available anywhere else in the solar

industry Bringing together industry professionals to the best B2B solar events in North America, including

Solar Power International and the regionally focused PV America Helping the SEIA members participate in the political process through the SolarPAC Assisting members of the media with any solar-related information relevant to their stories

SEIA and Efforts for Sustainability- Overall Committees and areas of work related to sustainability

The SEIA Environment, Health, & Safety Committee was developed to address all sustainability, environmental, health, and safety topics in the solar industry. The Committee consists of four sub-groups: Environmental & Social Responsibility Working Group, Codes & Standards Working Group, PV Recycling Working Group, and the Installer Safety & Workforce Development Working Group. Through these groups, the SEIA membership reviews a wide variety of topics including recycling, supply-chain sustainability, building codes, product standards, fire safety, and installer safety.The Environmental & Social Responsibility Working Group addresses all items of sustainability and corporate social responsibility. The major project of this group has been the development of the Solar Industry Commitment to Environmental & Social Responsibility.The Codes & Standards Working Group reviews all solar-related building codes and product standards, and submits comments on behalf of the SEIA membership. For example, the Working Group has submitted comments on the National Electrical Code, the International Building Code, and the International Green Construction Code.

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The PV Recycling Working Group is currently researching policy options for recycling in the U.S., and monitoring recycling policies in the European Union.The Installer Safety & Workforce Development Working Group is focused on reviewing federal safety regulations, and disseminating information regarding safety best practices. The Working Group has developed a SEIA Webinar Series focused on safety information, and proper application of federal and state regulations.

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About SEIA’s the Solar Commitment

The Solar Energy Industries Association (SEIA)SEIA is committed to continuous progress of environmental and social responsibility in the solar industry. The Solar Commitment defines common practices and expectations for all solar industry participants, including manufacturers, suppliers, subcontractors, and customers in the solar value chain. Joining in the Solar Commitment can benefit solar energy industry companies by:

» Ensuring that the solar industry continues to operate in accordance with our values. (PERHAPS NEED TO LIST SOME OF THESE VALUES)

» Enhancing credibility and trust with investors, customers, and regulators, all of which are increasingly looking for broad, objective measures of sustainability. Companies that participate will gain more confidence that will protect the brand in times of difficulty. Those which don't participate may stand out appear negligent. as laggards.

» Furthering efficiency and innovation. Participation will help to provide a roadmap for planning and resource allocation that will steer the company towards enhanced resource utilization, shared value, and governance. Fundamentally, this is a management tool aimed to build capacity for the company and its suppliers alike to more strategically and cost-effectively approach and execute sustainability.

» Exercising Industry influence. Participation "brings the company to the table," allowing it to be part of essential discussions shaping the future of sustainability for solar. This may hold keys to fruitful collaboration and learning from peers and industry networks, and increase the chances of establishing powerful cross-sector alliances

Therefore SEIA’s the Solar Commitment will support:

» Articulation of a business case and raising awareness in the solar industry: SEIA will develop a clear communications rationale, context, and protocol to articulate the business value of investing in efforts in social and environmental responsibility for the solar industry. This effort will include collecting and sharing case studies as part of the other two program areas—capacity building and transparency.

» Implementation support and tools for capacity building: SEIA will create industry-appropriate tools, guidelines and resources to cost-efficiently manage, report, on and improve implementation of the Solar Commitment. This will include a “first year” of the programthe Founding Year of the Solar Commitment and an ongoing year-end review that will determine necessary tools to help ParticipantSolar Participants on the road to continuous improvement. SEIA will explore cost effective ways to share information, share resources, and issue guidance, where possible, for thearticipant Solar Participants.

» Performance indicators and transparency: SEIA, with the Solar Commitment Advisory Group, will develop a succinct yet material set of performance indicators during the “first year”The Founding Year that aim to drive continuous improvement, enhance transparency and accountability of the solar industry. Companies will report against the indicators annually.

The Commitment consists of two parts:

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Part 1 Solar Specific Topics: Part 1 articulates items that are of particular interest to the solar industry and/or its stakeholders. Part 1 may include themes that are also addressed in Part 2.

Part 2 Core Compliance: Part 2 provides a broad set of foundational expectations for sustainability. In order to reduce duplication, promote harmonization, and advance shared approaches, SEIA has adopted the Electronics Industry Code of Conduct (“EICC”) V.3.0 (developed by the Electronic Industry Citizenship Coalition) as its core compliance standards for Labor, Health & Safety, the Environment, Management Systems, and Ethics (see appendix for more information on use of the EICC as part of this Commitment).

The full Solar Commitment is featured in the Annex of this Handbook.

The Founding Year: Commitment Requirements for ParticipantSolar Participants

All solar industry companies committed to improving social and environmental responsibility are encouraged to adopt the Solar Commitment. (SEIA membership is not required). The Solar ParticipantSolar Participant requirements are:

1. Indicating your interest: Entities intending to participate need to submit a letter of intent to SEIA. The letter needs to be signed by an Executiveexecutive- level representative and must include:

a. Endorsement and adoption to of the Solar Commitment through documentation indicating the Solar Commitment as the entity’s standard standard/or code of conduct, or by providing documentation of a pre-existing company policy or code of conductstandard/code that conforms to the Solar Commitment. as a minimum standard.

b. Commitment that the entity communicates the Solar Commitment or equivalent policystandard/code of conduct to its direct, first first-tier1 suppliers at minimum, by disclosing a transparent method for supplier selection. according to...

c. Commitment to participate in the development of the key performance indicators (KPIs) as part of the EHS Committee with the Advisory Group in the first yearFounding Year of the Solar Commitment. of the program’s development.

d. Commitment that the entity Solar Participant will proactively manage adherence to the Solar Commitment through providing data and reporting against the agreed KPIs. (See also “Tracking Solar Participant Progress” Section.) Drop in option 1 or option 2 from “Tracking Progress Section” and refer to the section.

e. Agreement to the principles of continuous improvement as described in the ‘definition of terms’.f. Proactively management of first-tier your Tier 1 suppliers to adhere to the requirements set forth in the

commitment Solar Commitment (through risk assessment, auditing, corrective action plans, training/capacity development).

g. Provide supporting documentation, if requested, to support the Solar Commitments.2. SEIA will confirm the entity’s request for participation upon receiving a letter of intent including all

required elements.

1 For the purposes of the Solar Commitment “First First-Tier suppliers” are considered to be suppliers who ParticipantSolar Participant company manages directly and who provide products or services that are key to the ParticipantSolar Participant’s solar business.

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3. Upon confirmation, SEIA will post ParticipantSolar Participant logos on its website and the ParticipantSolar Participant will declare on its website its support and adoption of the Solar Commitment.

4. The company must communicate internally the requirements of the Solar Commitment to relevant departments and organizations.

While SEIA, the Members and the Advisory Group will be discussing and agreeing the relevant program requirements over the first yearFounding Year of the Solar Commitment program development, we expect the following elements, at minimum, to be included in the final program after the first yearFounding Year:

Commitment to transparency: SEIA is committed to open and transparent reporting of the Solar Commitment. ParticipantSolar Participants are required to submit annual data on their progress toward meeting performance measurementsthe Key Performance Indicators as informed by the Advisory Group, the SEIA EHS Committee and approved by the SEIA Board. Reports of Key Performance Metrics by ParticipantSolar Participants is made publicly available through the SEIA website.

Commitment to continuous improvement: SEIA is committed to continually updating the Solar Commitment to meet the needs of the industry. A review and improvement process will be reviewed by the EHS Committee and Advisory Group. Address issues. Where necessary transparently report any follow up or improvement activities during the annual survey process.

Commitment to sharing best practices: We consider standards such as the ISO 14000, and SA8000, and equivalent standards, etc as to be best practicesmeasures of focus in the area of sustainability. If your organization has been certified with these standards, we will encourage you indicate this through your reporting. ParticipantSolar Participants also are required to share case studies and/or participate in shared learning opportunities within SEIA.

SEIA membership is not required to become a participantSolar Participant to the Solar Commitment.

Timeline for ParticipantSolar Participant Implementation

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Governance of the Solar CommitmentThe Solar Commitment program is managed by the Environment, Health and Safety (EHS) Committee of the Solar Energy Industries Association (SEIA). The EHS Committee is responsible for:

» Making recommendations (by consensus) for any changes to governance, program, or requirements of the Solar Commitment to the Board for Board consideration and vote.

» Working with an Advisory Group on input, agreement and communications (with SEIA Administration where appropriate) to the Solar Commitment per the Advisory Group Terms of Reference.

» Managing (with SEIA Administration where appropriate) Solar Commitment Program Requirements including but not limited to:

o Reviewing the Kkey Pperformance Iindicators for reporting every 3 years through the agreed process.o Reviewing the Solar Commitment parts 1 & 2 through the agreed process.» Formally voicing concerns over the progress or behavior of any ParticipantSolar Participant not fulfilling

Program Requirements. for Board consideration and vote.»

» The SEIA Board has responsibility to vote on:» The approval of the Solar Commitment » Any of Solar Commitment changes in content, program, participation or purpose. » The Advisory Group representatives

All rules pertaining to Board compositionAdvisory Group voting and quorum follow SEIA’s bylaws.

Solar Commitment Advisory Group StructureA key part of the Solar Commitment is the Advisory Group that informs the development and use of the Solar Commitment and the Key Performance Indicatorsperformance indicators for ParticipantSolar Participants to report on annually. Its primary purpose is to:

» Provide guidance and advice on a range of CSR corporate social responsibility (CSR) matters pertinent to the Solar Commitment.

» Act as a “sounding board” for communication and engagement strategies on key CSR and reputational risks.

» Provide input on key performance indicators (KPIs)Key Performance Indicators that will measure continuous improvement of the Solar Commitment.

» Review current policies and position statements, and inform decisions for future policies and position statements with regard to the Solar Commitment.

» Advise on stakeholder relationships and targeted engagement with specific stakeholder groups.» Provide a public statement on the KPIs and review process to the Solar Commitment report.

The Advisory Group shall be appointed by consensus by the EHS Committee with Board for approval.The Advisory Group shall consist of 5-7 independent, external members of a Non-Governmental Organization (NGO), Socially Responsible Investment (SRI) firm, Business community representativeLabor Union, or Academic Institution. At least one member from at least three of these categories must be reflected in composition of the Advisory Group at all times. The Advisory Group reports to the EHS Committee Committee and the SEIA Board.and the EHS Committee Chair has authority to make decisions on behalf of the EHS Committee with the Advisory Group.

The role of the Advisory Group is advisory in nature. All decisions are recommendations for SEIA’s EHS the EHS Committee to consider and submit to the Board of Directors for final approval.

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The Advisory Group is intended to meet for three years. Either party reserves the right to discontinue the relationship with or without cause. Resignation by a representative shall be tendered to the EHS Committee Chair and the representative may nominate a successor for EHS Committee consideration and Board vote.

A review of progress will take place each year to evaluate the achievements of the Advisory Group as well as the advisors themselves. The Advisory Group shall meet two times a year by teleconference and one time a year in-person. Advisory Group representatives are reimbursed for travel expenses only. All meeting minutes are publicly available.

All participantSolar Participants must show a good faith commitment towards the creation of agreed KPIs and means of transparency reporting them that supports the vision of the SOLAR Solar Commitment. All Aadvisors will be required to sign a non-disclosure agreement upon agreement.

Communicating about the Solar Commitment

SEIA acknowledges Solar ParticipantParticipants publicly on its website once the ParticipantSolar Participant has submitted its letter indicating its interest and SEIA has acknowledged the entity’s participation. Solar ParticipantParticipants will indicate their participation in the SEIA Solar Commitment on its website and may indicate participation in its other reporting processes.

Tracking Solar Participant Progresscompany progress: Solar Participant reportingSEIA is committed to open and transparent reporting of the Solar Commitment. SEIA is also committed to the continuous improvement principle that its Solar Commitment ParticipantParticipants will be striving toward. ParticipantSolar Participants are required to submit data against the KPIs that will be defined by the EHS Committee with the Advisory Group, and approved by the SEIA Board. The benchmark of Key Performance Indicators will be made publicly available through the SEIA website and Solar ParticipantParticipants will report annually against them.

Option 1:SEIA believes that transparency is one of the fundamental tools to show an entity’s commitment and progress toward implementing the Solar Commitment. SEIA understands that ParticipantSolar Participants will be at different levels of implementation. as they become a Solar Participant. In order to demonstrate continuous improvement, Solar ParticipantSolar Participants

In order to progress continuous improvement, Solar Participants have up to three years from the date of adoption to fully report on all Key Performance Indicators.ir

Option 2:SEIA believes that transparency is one of the fundamental

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Membership Ffees and paymentCurrently, Participation participation in the Solar Commitment is free to any entity in the solar industry value chain. A Solar Participant Participant need not be a SEIA member.

Role of Audits in the SEIA Solar CommitmentTo drive accountability and verification of ParticipantSolar Participant and their supplier practices SEIA recommends that companies develop auditing processes or that they integrate Solar Commitment requirements into their existing auditing practices. See the “Resources” section for examples of sustainability auditing programs and agencies.

Grievance Policy1. SEIA will alert the Solar ParticipantSolar Participant that it has received a claim and provide all available

information on that claim.2. SEIIEA Solar ParticipantParticipant Company is required to:a. Verify the legitimacy of the claim through investigation/audit.b. Identify primary issues of the claim and any corrective action needed.c. Instigate corrective action, as necessary.d. Report to SEIA what corrective action took place and when it was completed.e. SEIA will report annually on any corrective actions instigated through third party claims.

Reviewing the Solar Commitment Program

The Solar Commitment Program will be reviewed annually by the EHS Committee, and for the first three years of the Program, by the Advisory Group as well. Specifically, the EHS Committee will review the Commitment language and Key Performance Indicators for continued applicability, and also review the Reporting and Grievance processes. Feedback from the Solar Participants will be accounted for in the review process.The EHS Committee has responsibility for managing the Solar Commitment Program.

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Appendix

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Solar Industry Commitment to Environmental & Social ResponsibilityThe solar energy industry delivers sustainability solutions to customers by producing energy with low greenhouse gas impacts, improving energy security, and creating jobs and economic development. These considerations, however, are only a small part of the industry’s role in sustainability. More broadly, the solar energy industry has a responsibility to mitigate and manage its full range of social and environmental impacts, which include respecting the human rights of workers, ensuring that the rights of communities and other stakeholders are respected, and making business operations safe and environmentally responsible.

Taking this responsibility seriously is essential for advancing several strategic aims for individual solar companies as well as the industry as a whole:

To gather the broad support needed from customers, investors, communities, government agencies, and media to enable the sector’s growth;

To position the growing sector for integrating the most efficient and effective approaches to sustainability management while it is still young and flexible; and

To establish a generally accepted measurement framework that allows industry companies to differentiate themselves through investments which are transparent, credible and comparable.

To advance comprehensive sustainability performance of the solar industry in support of the above aims, the Solar Energy Industries Association (SEIA) has developed the Commitment for Environmental and Social Responsibility (“the Commitment”).2 The Commitment defines common practices and expectations for all solar industry participants, including manufacturers, suppliers, subcontractors, and customers in the solar value chain.

The Commitment consists of two parts:

Part 1 Solar Specific Topics: Part 1 articulates items that are of particular interest to the solar industry and/or its stakeholders. Part 1 may include themes that are also addressed in Part 2.

Part 2 Core Compliance: Part 2 provides a broad set of foundational expectations for sustainability. In order to reduce duplication, promote harmonization, and advance shared approaches, SEIA has adopted the Electronics Industry Code of Conduct (“EICC”) V.3.0 (developed by the Electronic Industry Citizenship Coalition) as its core compliance standards for Labor, Health & Safety, the Environment, Management Systems, and Ethics (see appendix for more information on use of the EICC as part of this Commitment).

By adopting the Commitment, a company will publically declare its support and implement the practices articulated, and thus will become a participant (“Participant”). A Participant shall also, at a minimum, require its next tier suppliers to acknowledge and strive to meet the Commitment.

In addition to implementing the Commitment in its entirety, Participants, in all of their activities, must operate in full compliance with the laws, rules and regulations of the countries in which they operate. However, the Commitment encourages Participants to go beyond legal compliance, drawing upon internationally recognized standards, to advance social and environmental responsibility. As part of the Commitment, it is expected that participants will develop transparent processes for communication with key stakeholders on relevant social and environmental impacts. In addition, Participants should commit

2 The Commitment is not intended to create new and additional third party rights, including for workers.

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to identifying best practices on emerging issues through industry dialogue, raising awareness about them, and advancing continuous improvement over time.3

SEIA is committed to ongoing engagement with the industry and stakeholders in the continued development, improvement, and implementation of the Commitment.

Part I: Solar Specific Topics

1) Human Rights In accordance with the United Nations Guiding Principles on Business and Human Rights and the Universal Declaration of Human Rights, Participants are expected to operate with respect for human rights and establish appropriate policies and processes to avoid infringement on human rights through Participant operations or business relationships. Participant should track and make available to relevant stakeholders information on their human rights performance.

2) Electrical Safety Participants must comply with electrical design and installation standards (e.g. the IEC/NEC or equivalent) to ensure electrical safety, including when systems are installed in ground-mount (free-field) or rooftop environments.

3) Energy and Environment Participants should actively work to reduce the consumption of natural resources including raw materials, water, and energy taking into consideration the entire product life-cycle from raw material sourcing through end-of-life. Scrap materials and end of life products should be reused or recycled through public or private programs. Key environmental impacts of manufacturing processes, product technology or key business operations should be identified and appropriate controls should be used to minimize these impacts including tracking water use, energy use, and related greenhouse gas emissions, while maximizing energy efficiency throughout business operations. Participants should make available to relevant stakeholders information on all of these processes and activities.

4) Fall ProtectionParticipants must comply with all applicable fall prevention requirements including, as relevant, fall prevention safety plans, training, monitoring, mitigation activities, corrective action plans as well as any additional activities to eliminate fall risk.

5) Reporting MisconductIf a supplier4 believes that anyone acting on behalf of the company requesting adherence to the Commitment is engaged in illegal or unethical conduct, the supplier should report this to the company. A good-faith report of suspected misconduct will not adversely impact the supplier.

Part II: Code for Core Compliance

LABOR

Participants are committed to uphold the human rights of workers, and to treat them with dignity and respect as understood by the international community. The recognized standards, as set out in the

3 Initial priority topics include (1) installation, (2) materials and chemical use, and (3) lifecycle energy impacts.

4 Supplier is defined as a company who is asked to provide a product or service for the company requesting adherence to this Commitment.

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annex, were used as references in preparing the Code and may be a useful source of additional information.

The labor standards are:

1) Freely Chosen EmploymentForced, bonded or indentured labor or involuntary prison labor shall not to be used. All work will be voluntary, and workers shall be free to leave upon reasonable notice. Workers shall not be required to hand over government-issued identification, passports or work permits to the Participant or Labor Agent as a condition of employment.

2) Child Labor AvoidanceChild labor is not to be used in any stage of manufacturing. The term “child” refers to any person under the age of 15 (or 14 where the law of the country permits), or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. The use of legitimate workplace apprenticeship programs, which comply with all laws and regulations, is supported. Workers under the age of 18 shall not perform work that is likely to jeopardize the health or safety of young workers.

3) Working HoursStudies of business practices clearly link worker strain to reduced productivity, increased turnover and increased injury and illness. Workweeks are not to exceed the maximum set by local law. Further, a workweek should not be more than 60 hours per week, including overtime, except in emergency or unusual situations. Workers shall be allowed at least one day off per seven-day week.

4) Wages and BenefitsCompensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. In compliance with local laws, workers shall be compensated for overtime at pay rates greater than regular hourly rates. Deductions from wages as a disciplinary measure shall not be permitted. The basis on which workers are being paid is to be provided in a timely manner via pay stub or similar documentation.

5) Humane TreatmentThe Participant’s disciplinary policies and procedures shall be clearly defined and communicated to workers. There is to be no harsh and inhumane treatment, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers: nor is there to be the threat of any such treatment.

6) Non-DiscriminationParticipants should be committed to a workforce free of harassment and unlawful discrimination. Companies shall not engage in discrimination based on race, color, age, gender, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership or marital status in hiring and employment practices such as promotions, rewards, and access to training. In addition, workers or potential workers should not be subjected to medical tests that could be used in a discriminatory way.

7) Freedom of AssociationOpen communication and direct engagement between workers and management are the most effective ways to resolve workplace and compensation issues. Participants are to respect the rights of workers to associate freely, join or not join labor unions, seek representation, join workers’ councils in accordance with local laws. Workers shall be able to communicate openly with management regarding working conditions without fear of reprisal, intimidation or harassment.

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HEALTH and SAFETYParticipants recognize that in addition to minimizing the incidence of work-related injury and illness, a safe and healthy work environment enhances the quality of products and services, consistency of production and worker retention and morale. Participants also recognize that ongoing worker input and education is essential to identifying and solving health and safety issues in the workplace.

Recognized management systems such as OHSAS 18001 and ILO Guidelines on Occupational Safety and Health were used as references in preparing the Code and may be a useful source of additional information.

The health and safety standards are:

1) Occupational SafetyWorker exposure to potential safety hazards (e.g., electrical and other energy sources, fire, vehicles, and fall hazards) are to be controlled through proper design, engineering and administrative controls, preventative maintenance and safe work procedures (including lockout/tagout), and ongoing safety training. Where hazards cannot be adequately controlled by these means, workers are to be provided with appropriate, well-maintained, personal protective equipment. Workers shall not be disciplined for raising safety concerns.

2) Emergency PreparednessEmergency situations and events are to be identified and assessed, and their impact minimized by implementing emergency plans and response procedures, including: emergency reporting, employee notification and evacuation procedures, worker training and drills, appropriate fire detection and suppression equipment, adequate exit facilities and recovery plans.

3) Occupational Injury and IllnessProcedures and systems are to be in place to prevent, manage, track and report occupational injury and illness, including provisions to: a) encourage worker reporting; b) classify and record injury and illness cases; c) provide necessary medical treatment; d) investigate cases and implement corrective actions to eliminate their causes; and e) facilitate return of workers to work.

4) Industrial HygieneWorker exposure to chemical, biological and physical agents is to be identified, evaluated, and controlled. Engineering or administrative controls must be used to control overexposures. When hazards cannot be adequately controlled by such means, worker health is to be protected by appropriate personal protective equipment programs.

5) Physically Demanding WorkWorker exposure to the hazards of physically demanding tasks, including manual material handling and heavy or repetitive lifting, prolonged standing and highly repetitive or forceful assembly tasks is to be identified, evaluated and controlled.

6) Machine SafeguardingProduction and other machinery is to be evaluated for safety hazards. Physical guards, interlocks and barriers are to be provided and properly maintained where machinery presents an injury hazard to workers.

7) Sanitation, Food, and HousingWorkers are to be provided with ready access to clean toilet facilities, potable water and sanitary food preparation, storage, and eating facilities. Worker dormitories provided by the Participant or a labor agent are to be maintained clean and safe, and provided with appropriate emergency egress, hot water

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for bathing and showering, and adequate heat and ventilation and reasonable personal space along with reasonable entry and exit privileges.

ENVIRONMENTALParticipants recognize that environmental responsibility is integral to producing world class products. In manufacturing operations, adverse effects on the community, environment and natural resources are to be minimized while safeguarding the health and safety of the public.

Recognized management systems such as ISO 14001, the Eco Management and Audit System (EMAS) were used as references in preparing the Code and may be a useful source of additional information.

The environmental standards are:

1) Environmental Permits and ReportingAll required environmental permits (e.g. discharge monitoring), approvals and registrations are to be obtained, maintained and kept current and their operational and reporting requirements are to be followed.

2) Pollution Prevention and Resource ReductionWaste of all types, including water and energy, are to be reduced or eliminated at the source or by practices such as modifying production, maintenance and facility processes, materials substitution, conservation, recycling and re-using materials.

3) Hazardous SubstancesChemical and other materials posing a hazard if released to the environment are to be identified and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.

4) Wastewater and Solid WasteWastewater and solid waste generated from operations, industrial processes and sanitation facilities are to be characterized, monitored, controlled and treated as required prior to discharge or disposal.

5) Air EmissionsAir emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations are to be characterized, monitored, controlled and treated as required prior to discharge.

6) Product Content RestrictionsParticipants are to adhere to all applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances, including labeling for recycling and disposal.

MANAGEMENT SYSTEM

Participants shall adopt or establish a management system whose scope is related to the content of this Code. The management system shall be designed to ensure (a) compliance with applicable laws, regulations and customer requirements related to the participant’s operations and products; (b) conformance with this Code; and (c) identification and mitigation of operational risks related to this Code. It should also facilitate continual improvement.

The management system should contain the following elements:

1) Company CommitmentCorporate social and environmental responsibility policy statements affirming Participant’s commitment to compliance and continual improvement, endorsed by executive management.

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2) Management Accountability and ResponsibilityThe Participant clearly identifies company representative[s] responsible for ensuring implementation of the management systems and associated programs. Senior management reviews the status of the management system on a regular basis.

3) Legal and Customer RequirementsIdentification, monitoring and understanding of applicable laws, regulations and customer requirements.

4) Risk Assessment and Risk ManagementProcess to identify the environmental, health and safety5 and labor practice and ethics risks associated with Participant’s operations. Determination of the relative significance for each risk and implementation of appropriate procedural and physical controls to control the identified risks and ensure regulatory compliance.

5) Improvement ObjectivesWritten performance objectives, targets and implementation plans to improve the Participant’s social and environmental performance, including a periodic assessment of Participant’s performance in achieving those objectives.

6) TrainingPrograms for training managers and workers to implement Participant’s policies, procedures and improvement objectives and to meet applicable legal and regulatory requirements.

7) CommunicationProcess for communicating clear and accurate information about Participant’s policies, practices, expectations and performance to workers, suppliers and customers.

8) Worker Feedback and ParticipationOngoing processes to assess employees’ understanding of and obtain feedback on practices and conditions covered by this Code and to foster continuous improvement.

9) Audits and AssessmentsPeriodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of the Code and customer contractual requirements related to social and environmental responsibility.

10) Corrective Action ProcessProcess for timely correction of deficiencies identified by internal or external assessments, inspections, investigations and reviews.

11) Documentation and RecordsCreation and maintenance of documents and records to ensure regulatory compliance and conformity to company requirements along with appropriate confidentiality to protect privacy.

ETHICSTo meet social responsibilities and to achieve success in the marketplace, Participants and their agents are to uphold the highest standards of ethics including:

1) Business IntegrityThe highest standards of integrity are to be expected in all business interactions. Participants shall

5 Areas to be included in a risk assessment for environmental health and safety are production areas, warehouse and storage facilities, plant/facilities support equipment, laboratories and test areas, sanitation facilities (bathrooms), kitchen/cafeteria and worker housing/dormitories.

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prohibit any and all forms of corruption, extortion and embezzlement. Monitoring and enforcement procedures shall be implemented to ensure conformance.

2) No Improper AdvantageBribes or other means of obtaining undue or improper advantage are not to be offered or accepted.

3) Disclosure of InformationInformation regarding business activities, structure, financial situation and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices.

4) Intellectual PropertyIntellectual property rights are to be respected; transfer of technology and know-how is to be done in a manner that protects intellectual property rights.

5) Fair Business, Advertising and CompetitionStandards of fair business, advertising and competition are to be upheld. Appropriate means to safeguard customer information must be available.

6) Protection of IdentityPrograms that ensure the confidentiality and protection of supplier and employee whistleblower6 are to be maintained.

NOTE: Use of the EICC Code

The EICC Code provides guidelines for performance and compliance with critical CSR policies for the Information and Communication Technology (ICT) industry. The EICC Code was developed through a multi-stakeholder process and is now being used by over 40 well-known ICT brands and over 1000 of their suppliers, and it has been translated into sixteen languages.7 In order to minimize duplicity and use language that participants and stakeholders are familiar with, we have leveraged the EICC framework as a basis for the SEIA statement, and added unique issues for solar as are pertinent. We understand that the EICC Code is likely to evolve in the future, and we intend to take its advances under consideration as the SEIA statement evolves.

The following standards were used to develop the EICC Code of Conduct and may be a useful source of additional information. The following standards may or may not be endorsed by each Participant.

ILO Code of Practice in Safety and Health www.ilo.org/public/english/protection/safework/cops/english/download/e000013.pdf

National Fire Protection Agency www.nfpa.org/catalog/home/AboutNFPA/index.asp

ILO International Labor Standards www.ilo.org/public/english/standards/norm/whatare/fundam/index.htm

OECD Guidelines for Multinational Enterprises www.oecd.org

United Nations Convention Against Corruption www.unodc.org/unodc/en/crime_convention_corruption.html

United Nations Global Compact www.unglobalcompact.org

Universal Declaration of Human Rights www.un.org/Overview/rights.html

6 Whistleblower definition: Any person who makes a disclosure about improper conduct by an employee or officer of a company, or by a public official or official body.7 See http://www.eicc.info/EICC%20CODE.htm

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ISO 14001 www.iso.org

SA 8000 www.cepaa.org/

SAI www.sa-intl.org

Ethical Trading Initiative www.ethicaltrade.org/

OHSAS 18001 www.bsi-global.com/index.xalter

Eco Management & Audit System www.quality.co.uk/emas.htm

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Frequently Asked Question – V1: The First YearFounding YearThis document outlines the initial elements that will make up an ‘FAQ’ document for SEIA’s commitment statement and its implementation by participantsSolar Participants. The aim of the document is to:

» Articulate more details about the program

» Answer basic questions that entities may have to consider joining the effort

» Provide awareness raising

Initial Sections of questions to be answered:

Participation

» What does it mean to participate? In the first yearFounding Year of the Solar Commitment, “members”Solar Participants (those who sign on for the first year of benchmark reporting with the intention of continuing with the Solar Commitment Participation requirements) will be required to:

o Submit an official letter of commitment from an executive representative, that includes agreement to participate in EHS Committee meetings, and help develop of KPIs, key tools, guidance documents, reporting mechanisms, etc. in collaboration with the Advisory Group.

o Endorse the Solar Commitment including executive executive-level support, – through an official letter of commitment from executive- level representative, or document showing compliance through pre-existing company procedures.

o Proactively manage company adherence to the Solar Commitment, – through reporting procedures determined between the EHS Committee and the Advisory Group.

o Require and proactively manage the company’s Tier 18 first-tier suppliers to adhere to the requirements set forth in the commitment Solar Commitment (training/capacity development, risk assessment, auditing, corrective action plans).

o Communicate internally through communications, education, training, the requirements of the Solar Commitment.

» What are the reporting requirements? Participating companies are required to share data according to the agreed KPIs for public reporting.

» What kinds of organizations can participate? The Solar Commitment is open to any entity in the solar value chain.

» How much does it cost? There is no Participation fee at this time.

» Do I have to be a SEIA member to participate? Any entity is encouraged to use the Commitment for their own purposes; SEIA will only recognize entities that have agreed to the Participation requirements in the Solar Commitment program. A company does not need to be a SEIA member to participate.

» Are SEIA members required to participate in the Commitment program? No. Participation in the SEIA Commitment is voluntary. However, SEIA encourages members and all entities in the solar value chain to participate.

8 Tier 1 suppliers doing business on your behalf. “provide services or products directly to Participant”

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» Can entities adopt the SEIA Commitment without Participating in the Program? The SEIA Commitment is a public document and may be used by any entity to progress social and environmental responsibility in the supply chain. However, only ParticipantSolar Participants will be recognized by SEIA and acknowledged on the SEIA website.

The Solar Commitment Statement

» When did SEIA adopt The Solar Commitment? this Commitment Statement? The Board of Directors adopted the Solar Commitment on December 14, 2011.

» What is the scope of the statement? Ethics, Labor, Health & Safety, Environment, Management Systems

» Do you require audits against the statement? SEIA recommends that ParticipatSolar Participantsing companies have auditing as an integral part of all supply chain management programs.

» Who was involved in developing the Statement? SEIA’s Environment, Health & Safety Committee, and External Stakeholders: Natural Resource Defense Council, Silicon Valley Toxics Coalition, Boston Common Asset Management, As You Sow, PG&E, Fotowatio, European Photovoltaic Industry Association, EU Joint Research Center; (list external stakeholders).

» Do I need to communicate this to my suppliers? YESYes -. ParticipantSolar Participants agree that the Commitment is communicated and agreed-upon with first first-tier suppliers. We encourage those suppliers to also communicate and have agreementimplement the Commitment further down the supply chain.

» How is this similar/ or different from existing supply chain initiatives such as the EICC? SEIA has consulted with internal and external stakeholders on how to drive continuous progress of supply chain social and environmental responsibility. Out of these discussions it became clear that 1) leveraging existing commitments and deriving lessons from other organizations is critical to progressing standards consistently, 2) to there is a need to prevent reduce the ‘reinvention of the wheel’ and 3) particular issues for solar industry need also to be addressed. Thus, Tthe SEIA Solar Commitment leverages the EICC code to progress relevant and familiar standards, while addressing some of the issues the solar industry in particular wants to address.topics specific to the solar industry. In addition, SEIA has committed to drive behavior through a transparency model in order to reduce costs for SEIA, drive ParticipantSolar Participant ownership for the Commitment implementation, and to provide leadership on transparency for the industry.

The Performance indicators

» How do you know ParticipantSolar Participants are implementing the Commitment? SEIA will publicly report against multi-stakeholder agreed Key Performance Indicators that is aimed to show continuous improvement toward the Commitment.

» Who was involved in creating the performance indicators? SEIA’s EHS Committee with the multi-stakeholder Advisory Board.

» When and how often do participantSolar Participants report against their indicators and to whom? In 2012, a baseline report will be publicly available for ‘ participants’Solar Participants. From there, SEIA will publish ParticipantSolar Participant reports on the KPIs annually.

Transparency

» When will reporting against the indicators be public? The first report will be published approximately December 2012 as a baseline report. The first year report will be published approximately June 2014.

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General

» Who can I contact for more information? Christine Covington, ccovington@seia.org, 202-556-2894

» Where can I get more information on the EICC Code of Conduct? The EICC Code of Conduct and all relevant guidance materials are available through the EICC website:

» http://www.eicc.info/eicc_code.shtml

Governance

» Does the Solar Program include a Ggrievance Mechanism? SEIA has the following process for handling grievances submitted by third parties:

o SEIA will alert the ParticipantSolar Participant Company to any third party claim

o SIEA ParticipantSolar Participant Company is required to:

Verify the legitimacy of the claim through investigation/audit.

Identify primary issues of the claim and any corrective action needed.

Instigate corrective action.

Report to SEIA what corrective action took place and when it was completed.

SEIA will report annually on any corrective actions instigated through third party claims.

o Who is part of the Advisory Board and what are their main roles/responsibilities?

» Why is the Commitment voluntary and not a requirement for SEIA membership?

» What will be the process for changing requirements to the Commitment Statement language, the KPIs, or for changing implementation practices?

» What if a SEIA member company repeatedly violates the commitment or has egregious violations? SEIA’s EHS Committee is responsible for formally voicing concerns over the progress or behavior of any ParticipantSolar Participant not fulfilling Program Requirements for Board consideration and vote. The Board may remove a ParticipantSolar Participant from the program through a supermajority vote.

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Template/Example Letter of Intention to Participate

Dear XXX

Signed,

CEO of X Solar Manufacturing Company

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Terms of Reference for an Advisory Group

1. Introduction

To advance comprehensive sustainability performance of the solar industry, the Solar Energy Industries Association (SEIA) has developed the Solar Industry Commitment tofor Environmental and Social Responsibility (“the Solar Commitment”).9 The Solar Commitment defines common practices and expectations for all solar industry participantSolar Participants, including manufacturers, suppliers, subcontractors, and customers in the solar value chain.

SEIA is committed to demonstrated continuous improvement towards the Solar Commitment through open and transparent reporting. ParticipantSolar Participants of the Solar Commitment program will be required to submit annual data on their progress toward meeting the Solar Commitment through Key Performance Metrics Indicators that will be made publicly available through the SEIA website annually.

SEIA, with the Solar Commitment Advisory Group, will develop a succinct yet material set of performance indicators during the “first year”Founding Year. This document outlines the terms of reference for the Advisory Group that will work in collaboration with the Environmental, Health, & Safety Committee of SEIA, and ultimately the SEIA Board to:

» Identify material key Key performance Performance indicators Indicators (KPISKPIs) for public reporting of the Solar Commitment.

» Provide recommendations to SEIA on key issues of consideration.

» Provide a public statement on the process and result of the KPI development and first benchmark report.

The work of the Advisory Group consists of five phases:1. Assembling the Solar Commitment Advisory Group to contribute to, guide, and agree to the Key

Performance Indicators (KPI). 2. Generating a KPI framework outlining the possible material categories for reporting, keeping in mind

that the KPIs should be the most pertinent for the industry.3. Participating in the consultation process to get input and feedback on the framework and material KPIs.4. Inputing IProviding input and agreeing to final KPIs for the Solar Commitment “‘benchmark data” launch.5. Writing a public statement with other Advisory Group members on the process and result of the KPIs

and first benchmark report.6. Continuing to advise on the reporting until the end of the Advisory Group term (in agreement with the

governance rules of the Advisory Group).

This paper outlines draft Terms of Reference, objectives, roles and responsibilities criteria for the Solar Commitment Advisory Group.

9 The Commitment is not intended to create new and additional third party rights, including for workers.

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2. Terms of reference for the Advisory Group2.1 ObjectivesThe purpose of the Advisory Group is to:

» Shape the research, insights and assist in the creation of the Key Performance Indicators for the Solar Commitment.

» Agree upon the KPIs for ParticipantSolar Participants to report on for the Benchmark report.» Provide insights and guidance on key corporate social and environmental responsibility matters

relevant to the solar industry. » Review, if appropriate, current policies and position statements of the Solar Commitment.

2.2 Role of Advisory Group membersThe role of Advisory Group members includes:

» Participate in a good faith effort in the Advisory Group through dedication of time to input on the Key Performance Indicators for the Solar Commitment.

» Provide advice on the management and implementation of the Commitment, where appropriate.

» Agree in good faith upon the Key Performance Indicators of the Solar Commitment.» Provide a public statement on the process and result of the KPI development and benchmark report.

2.3 Responsibilities of the Advisory Group

The Advisory Group is responsible for: » Meet in-person once a year to discuss and agree in detail upon the KPIs.» Participate in two conference calls per year to review progress towards achieving this target.» Review the benchmark report against the KPIs that first Participating CompaniesSolar Participants

submit.» Contribute to the Advisory Group public statement about the process and initial benchmark KPIs.

3. Governance and remuneration of the Advisory GroupThe Advisory Group shall be appointed by consensus by the EHS Committee with Board for approval.The Advisory Group shall consist of 5-7 independent, external members of a Non-Governmental Organization (NGO), Socially Responsible Investment (SRI) firm, Labor Union, Business representative, or Academic Institution. At least one member from at least three of these categories must be reflected in composition of the Advisory Group at all times. The Advisory Group reports to the EHS Committee and the EHS Committee Chair has authority to make decisions on behalf of the EHS Committee with the Advisory Group.and Board.

The role of the Advisory Group is advisory in nature. All decisions are recommendations for SEIA’s EHSthe EHS Committee to consider and submit to the Board of Directors for final approval.

The Advisory Group is intended to meet for three years. Either party reserves the right to discontinue the relationship with or without cause. Resignation by a representative shall be tendered to the EHS Committee Chair and the representative may nominate a successor for EHS consideration and Board vote.

A review of progress will take place each year to evaluate the achievements of the Advisory Group as well as the advisors themselves. The Advisory Group shall meet two times a year by teleconference and

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one time a year in-person. Advisory Group representatives are reimbursed for travel expenses only. All meeting minutes are publicly available.

All participants Advisors must show a good faith commitment towards the creation of agreed KPIs and means of transparency reporting them that supports the vision of the SOLAR Solar Commitment. All advisors Advisors will be required to sign a non-disclosure agreement upon agreement.

4. Solar Commitment Advisory Group support

SEIA is responsible for the overall operating effectiveness of the Solar Commitment. SEIA will support the Advisory Group and the EHS Committee by:

» Co-ordinate the agenda in association with the EHS Committee Chair.» Record the minutes, actions and any impacts on the delivery objectives. » Coordinate meetings, circulating meeting dates, agendas, minutes etc.» Promote and encourage attendance at the meetings of the Advisory Group.» Coordinate all activities with the facilitator (if applicable).

5. Information management and transparency

» Once the Terms of Reference are approved by Advisory Group members, the names, roles and organizational affiliations of the Advisory Group will be posted on the SEIA Solar Commitment website and will be published via Press Release.

» Any information Advisory Group members choose to share with the group will not be included in the Solar Commitment publications or case studies unless permission is expressly given.

» Minutes will be circulated to the Solar Commitment Advisory Group members for comment prior to finalisation, approval and posting to the SEIA website.

» Advisory Group members will be informed of potential media activity and will have the opportunity to provide advance input to written communications, such as press releases.

» All Advisory Group members will be required to sign an Non-Disclosure Agreement to participate. » To enable sharing of information within the group, the Chatham House10 rule applies at the Solar

Commitment Advisory Group meetings.

10 “When a meeting, or part thereof, is held under the Chatham House Rule, participantSolar Participants are free to use the information received, but neither the identity nor the affiliation of the speaker(s), nor that of any other participantSolar Participant, may be revealed."

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