3TG Conflict Minerals Policy

It is the policy of Sunpower Group Holdings Ltd to source components and materials from only companies who provide confirmation of compliance to the requirements of Conflict Minerals (3TG) as detailed within Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“the Dodd-Frank Act”).

Introduction to the Conflict Minerals Legislation

  • Sunpower Group Holdings Ltd is committed to sourcing components and materials from companies that share our values on human rights issues, ethics and environmental responsibility. On August 22, 2012, the final rule regarding sourcing of conflict minerals under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“the Dodd-Frank Act”) was approved by the U.S. Securities and Exchange Commission (“SEC”).
  • The rule imposes reporting requirements on publicly traded companies subject to the SEC to report annually the presence of conflict minerals originating in the Democratic Republic of the Congo (“DRC”) or adjoining countries (“Covered Countries”) in the products they manufacture or contract to manufacture whereby the conflict minerals are necessary to the functionality or production of a product.

What is Sunpower Group Holdings Ltd Doing?

  • Sunpower Group Holdings Ltd has always supported an industry-wide approach to addressing social responsibility issues throughout the supply chain; this includes metals that are most abundant in electronics, including the “conflict minerals” used to make tantalum, tin, tungsten, and gold.
  • Tracing materials back to their mine of origin is a complex aspect of responsible sourcing in the electronics industry supply chain and we are reliant on our supply chain to support us by following our lead to source conflict-free minerals.
  • Due to the enormity of Sunpower Group Holdings Ltd and its suppliers’ respective supply chains, it will take time for many suppliers to verify the origin of conflict minerals used in their components and materials. Using our supply chain due diligence process and continuing our partnership with our supply chain we will further augment our goals.

Sunpower Group Holdings Ltd Supply Chain Expectation

  • Sunpower Group Holdings Ltd expects its suppliers to commit to Sunpower Group Holdings Ltd responsible sourcing of minerals requirements and to reasonably assure that the tantalum, tin, tungsten and gold in the products they manufacture are conflict free. Sunpower Group Holdings Ltd expects suppliers to establish their own due diligence program to ensure conflict-free supply chains.
  • Suppliers must ensure that all parts used to manufacture products supplied to Sunpower Group Holdings Ltd originated from certified conflict-free smelters validated as compliant to the EICC Conflict Free Smelter (CFS) protocol, using the CFS Compliant Smelter List. The CFS program is a global program where an independent third party evaluates a smelter’s procurement activities and determines if the smelter demonstrated that materials they processed originated from conflict-free sources. Through this industry collaborative effort, smelters are audited globally.
  • The list of compliant smelters and refiners is posted at conflictfreesmelter.org