Low Carbon Supplier Code of Conduct

Low Carbon is committed to respecting the highest standards of labour, human rights, environmental, and ethical conduct. We expect our suppliers, contractors and our suppliers’ and contractors’ subsidiaries, affiliates, subcontractors, and sub-tier suppliers who provide goods or services to Low Carbon or for use in or with Low Carbon products ("Suppliers") to provide safe working conditions, treat workers with dignity and respect, act fairly and ethically, and adopt environmentally responsible practices in all their operations.

Low Carbon requires its Suppliers to operate in accordance with the principles and requirements, as applicable, in this Low Carbon Supplier Code of Conduct (the “Code”), and in full compliance with all Applicable Laws and Regulations. As part of Low Carbon’s development strategy, we actively seek Suppliers who demonstrate a commitment to responsible and sustainable business practices which surpasses minimum standards.

Our Guiding Principles

This Code is rooted in internationally recognised human rights, as outlined in the United Nations' International Bill of Human Rights and the International Labour Organization's Declaration on Fundamental Principles and Rights at Work. Low Carbon is deeply committed to respecting human rights, as laid out in our company-wide Human Rights Policy, developed in accordance with the UN Guiding Principles for Business and Human Rights (UNGPs). Low Carbon’s commitment to the principles set out in this Code is also evidenced by its company-wide adherence to numerous standards and initiatives such as: Principles for Responsible Investment (PRI), Corporate Leaders Group (CLG), and the Solar Stewardship Initiative (SSI).

Fundamental to adopting the Code is the understanding that a business, in all of its activities, must operate in full compliance with the laws, rules, and regulations of the countries in which it operates. The Code also encourages Suppliers to go beyond legal compliance, drawing upon internationally recognised standards, in order to advance social and environmental responsibility and business ethics. In no case can complying with the Code violate local laws. If, however, there are differing standards between the Code and local law, Low Carbon defines conformity as meeting the higher standard.

By adhering to this Code, Suppliers are expected to meet the items herein as a minimum standard. If there are circumstances where a Supplier is yet to be compliant with the terms of the Code, it must inform Low Carbon pursuant to paragraph 47 below and Low Carbon will work with the Supplier on an improvement plan if appropriate. If it is not possible or appropriate in Low Carbon’s view to resolve the issue through an improvement plan or within a reasonable timescale, Low Carbon may review the terms of the engagement and Low Carbon reserves the right to review Supplier’s internal policies, review procedures, and any other mechanism thought to be appropriate at Low Carbon’s sole discretion.

Low Carbon assesses its Suppliers' compliance with the Code, and any violations may put the Supplier's relationship with Low Carbon at risk.

Labour and Human Rights

Low Carbon firmly believes that all workers in its supply chain deserve fair and ethical workplaces. Suppliers must uphold the highest standards of human rights, ensuring workers are treated with dignity and respect, as understood by the international community. This applies to all workers including temporary, migrant, student, contract, direct employees, and any other type of worker.

1. Freely Chosen Employment

1.1 Forced, bonded (including debt bondage) or indentured labour, involuntary or exploitative prison labour, slavery or trafficking of persons is not permitted. This includes transporting, harbouring, recruiting, transferring, or receiving persons by means of threat, force, coercion, abduction or fraud for labour or services.

1.2 Workers shall have no unreasonable restrictions placed on their freedom of movement, including unreasonable restrictions on entering or exiting company provided facilities, such as dormitories or living quarters.

1.3 All work must be voluntary, and workers shall be free to leave work at any time or terminate their employment without penalty if reasonable notice is given as per the worker's contract.

1.4 As part of the hiring process, all workers must be provided with a written employment agreement in their native language. The employment agreement should contain a description of the terms and conditions of employment.

1.5 Foreign migrant workers must receive the employment agreement prior to their departure from their country of origin. No substitution or changes in the employment agreement are allowed upon arrival in the receiving country, unless required by local law and provide equal or better terms.

1.6 Employers, agents, and sub-agents are prohibited from holding, destroying, concealing, or confiscating identity or immigration documents of workers, such as government-issued identification, passports, or work permits. Employers can only hold documentation if required by law, and workers should have access to their documents at all times.

1.7 Workers shall not be required to pay employers' agents or sub-agents' recruitment fees or other related fees for their employment. If any such fees are found to have been paid by workers, they shall be repaid to the worker.

2. Freedom of Association and Collective Bargaining

2.1 Suppliers shall respect the right of all workers to form and join trade unions of their own choosing, to bargain collectively, and to engage in peaceful assembly.

2.2 Where the right to freedom of association and collective bargaining is restricted under law, suppliers shall facilitate, and not hinder, the development of parallel means for independent and free association and bargaining.

2.3 Workers and/or their representatives shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation, or harassment.

3. Young Workers and Prevention of Underage Labour

3.1 Suppliers shall employ workers who meet the minimum legal age for employment or the age for completion of compulsory education, whichever is higher, and not below 15 years of age.

3.2 If child labour is identified, Suppliers shall provide appropriate assistance and remediation to ensure the transition of any child found performing child labour to quality education until they are no longer considered children.

3.3 Children and young persons under 18 shall not be employed at night or in hazardous conditions, in accordance with relevant ILO standards.

3.4 Adequate support and training shall be provided to all student workers. Suppliers may provide legitimate workplace apprenticeship programs for educational benefit that are consistent with Article 6 of ILO Minimum Age Convention No. 138 or light work consistent with Article 7 of ILO Minimum Age Convention No. 138.

3.5 In the absence of local law, the wage rate for student workers, interns, and apprentices shall be at least the same as other entry-level workers performing similar tasks.

4. Working Hours

4.1 Working hours must comply with national laws, collective agreements, and the provisions in paragraphs 4.2 to 4.6 below, whichever affords the greater protection for workers. Sub-paragraphs 4.2 to 4.6 are based on international labour standards.

4.2 Working hours, excluding overtime, shall be defined by contract, and shall not exceed 48 hours per week.

4.3 All overtime shall be voluntary. Overtime shall be used responsibly, taking into account all of the following:

4.3.1 The extent, frequency, and hours worked by individual workers and the workforce as a whole.

4.3.2 It shall not be used to replace regular employment.

4.3.3 Overtime shall always be compensated at a premium rate, which is recommended to be not less than 125% of the regular rate of pay.

4.4 The total hours worked in any seven day period shall not exceed 60 hours, except where covered by sub-paragraph 4.5 below.

4.5 Working hours may exceed 60 hours in any seven day period only in exceptional circumstances where all of the following are met:

4.5.1 this is allowed by national law;

4.5.2 this is allowed by a collective agreement freely negotiated with a workers’ organisation representing a significant portion of the workforce;

4.5.3 appropriate safeguards are taken to protect the workers’ health and safety;

4.5.4 the employer can demonstrate that exceptional circumstances apply such as unexpected production peaks, accidents or emergencies.

4.6 Workers shall be provided with at least one day off in every seven day period or, where allowed by national law, two days off in every 14 day period.

5. Wages and Benefits

5.1 Suppliers shall respect the rights of workers to a living wage and ensure that wages paid for a normal working week shall always meet at least a legal or industry minimum standard and shall be sufficient to meet the basic needs of workers and to provide some discretionary income.

5.2 Suppliers shall make wage payments that are timely, in legal tender and fully documented. All workers must receive an itemized pay slip for every pay period, showing the basis on which they are paid.

5.3 Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded.

6. Anti-Discrimination

6.1 Suppliers shall not discriminate against any worker based on age, disability, ethnicity, gender, marital status, national origin, political affiliation, race, religion, sexual orientation, gender identity, union membership, or any other status protected by applicable national or local law, in hiring and other employment practices.

6.2 Workers shall be provided with reasonable accommodation for religious practices.

6.3 Suppliers shall not require pregnancy or medical tests, except where required by applicable laws or regulations or prudent for workplace safety and shall not improperly discriminate based on test results.

7. Humane Treatment

7.1 Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited. Suppliers shall clearly define and communicate disciplinary policies and procedures in support of these requirements.

Health and Safety

Low Carbon strongly believes that every worker should be afforded a safe work environment. Low Carbon urges its Suppliers to adopt and maintain the highest possible standards of health and safety within its operations and management systems. Workers shall have the right to refuse unsafe work and to report unhealthy working conditions. Any reports of unhealthy or unsafe working conditions shall be appropriately considered and actioned.

8. Occupational Health and Safety Policy

8.1 Suppliers shall implement, communicate and regularly review a health and safety policy (being a document outlining a Supplier’s commitment and approach to managing health and safety in the workplace including outlining roles, responsibilities and arrangements) which:

8.1.1 is endorsed and supported by senior management through the provision of necessary training and resources and due consideration to health and safety implications in all business decisions;

8.1.2 is applied to all workers and visitors present in any area under Suppliers’ control; and

8.1.3 includes a commitment to comply with Applicable Law on workers’ health and safety, international standards, ISO45001 health and safety management systems and ILO Conventions on Occupational Health and Safety, including where relevant, ILO Conventions 155 and 1761.

9. Occupational Health and Safety Management

9.1 Worker potential for exposure to health and safety hazards, such as chemical, electrical, fire, vehicles, and fall hazards, shall be identified and assessed.

9.2 Hazards shall be mitigated using the hierarchy of controls, to determine the actions to best control exposures including eliminating the hazard, substituting processes or materials, implementing engineering and administrative controls, and providing ongoing occupational health and safety training.

9.3 Workers shall be provided with appropriate, well-maintained personal protective equipment when hazards cannot be adequately controlled by other means.

9.4 Pregnant women and nursing mothers shall be removed from high-hazard working conditions, and risks associated with their work assignments shall be reduced. Reasonable accommodations shall be provided for nursing mothers.

10. Emergency Preparedness and Response

10.1 Potential emergency situations and events shall be identified and assessed.

10.2 For each situation, Suppliers shall develop and implement emergency plans and response procedures that will minimize harm to life, environment, and property.

10.3 Emergency drills shall be conducted at least annually or as required by local law.

10.4 Emergency plans shall include fire detection and suppression equipment, clear egress, adequate exit facilities, and contact information for emergency responders.

11. Occupational Injury and Illness

11.1 Procedures and systems shall be in place to prevent, manage, track, and report occupational injury and illness cases.

11.2 Workers shall be encouraged to report incidents, and necessary medical treatment shall be provided.

11.3 Investigations shall be conducted to eliminate the causes of incidents, and corrective actions shall be implemented.

11.4 Suppliers shall take measures to facilitate the return of workers to work.

12. Industrial Hygiene

12.1 Worker exposure to chemical, biological, and physical agents shall be identified, evaluated, and controlled.

12.2 Opportunities to eliminate or reduce potential hazards shall be sought.

12.3 Hazards shall be controlled through proper design, engineering, administrative controls, and personal protective equipment.

12.4 Ongoing protective programs and educational materials shall be provided to workers.

13. Physically Demanding Work

13.1 Hazards associated with physically demanding tasks shall be identified, evaluated, and controlled.

13.2 Measures shall be taken to minimise risks related to manual material handling, heavy lifting, prolonged standing, and forceful assembly tasks.

14. Machine Safeguarding

14.1 Production and other machinery shall be evaluated for safety hazards.

14.2 Physical guards, interlocks, and barriers shall be provided and properly maintained to prevent worker injuries.

15. Sanitation, Food, and Housing

15.1 Workers shall have access to clean toilet facilities, potable water, and sanitary food preparation and storage facilities.

15.2 Worker dormitories, whether provided by Suppliers or a third party, shall be clean, safe, and provide appropriate facilities, including emergency egress, hot water, lighting, ventilation, storage accommodations, and personal space.

16. Health and Safety Communication

16.1 Workers shall receive appropriate health and safety information and training in their native language.

16.2 Health and safety-related information shall be clearly posted or made accessible to workers.

16.3 Workers shall be encouraged to raise concerns relating to Health and Safety without retaliation.


Low Carbon is committed to protecting the environment, and environmental responsibility is at the core of how Low Carbon operates. In keeping with that commitment, Suppliers shall develop, implement, and maintain environmentally responsible business practices.

17. Environmental Commitment

17.1 Suppliers shall be committed to protecting the environment and recognise that environmental responsibility is a fundamental aspect of their operations.

17.2 Suppliers' manufacturing operations will aim to minimise adverse effects on the community, environment, and natural resources, while prioritising public health and safety.

17.3 Suppliers will incorporate recognised management systems, such as the Eco Management and Audit System (EMAS) and ISO14001, as references to guide their environmental practices.

18. Compliance with Environmental Permits and Reporting

18.1 Suppliers shall obtain and maintain all necessary environmental permits, approvals, and registrations relevant to their operations.

18.2 Suppliers shall ensure compliance with the operational and reporting requirements of these permits.

19. Pollution Prevention and Resource Conservation

19.1 Suppliers will adopt practices to minimize or eliminate emissions, discharges of pollutants, and waste generation at the source.

19.2 Suppliers shall prioritise conservation of natural resources, including water, fossil fuels, minerals, and virgin forest products, through the implementation of practices such as modifying production, maintenance, and facility processes, materials substitution, re-use, conservation, recycling, or other suitable methods.

20. Safe Handling and Management of Hazardous Substances

20.1 Suppliers will identify, label and manage chemicals, waste, and other materials posing a hazard to humans or the environment to ensure safe handling, movement, storage, use, recycling, re- use, and disposal.

21. Effective Solid Waste Management

21.1 Suppliers shall implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle non-hazardous solid waste generated from their operations.

22. Control of Air Emissions

22.1 Suppliers shall identify, manage, reduce, and responsibly control all air emissions emanating from its operations that pose a hazard to the environment.

22.2 Suppliers shall conduct routine monitoring of the performance of its Air Emission control systems.

23. Efficient Water Management

23.1 Suppliers shall establish and implement a water management program that includes documenting, characterising, and monitoring water sources, usage, and discharge.

23.2 Opportunities for water conservation will be sought, and channels of contamination will be controlled.

23.3 Wastewater generated from Suppliers’ operations will be characterised, monitored, controlled, treated as required, and discharged or disposed of responsibly.

23.4 Routine monitoring of the performance of Suppliers wastewater treatment and containment systems shall be conducted to ensure optimal performance and compliance with regulations.

24. Energy Consumption and Greenhouse Gas Emissions

24.1 Suppliers shall collect and account for Greenhouse Gas (GHG) Scope 1 and Scope 2 emissions according to a recognized standard, such as the WRI/WBCSD Greenhouse Gas Protocol Corporate Accounting and Reporting Standard.

24.2 Suppliers shall make company level GHG emissions data available upon Low Carbon’s request.

24.3 Suppliers shall work towards accounting for material sources of indirect GHG Scope 3 emissions.

24.4 Suppliers shall provide environmental data per product/project (as applicable) in accordance with documentation provided by Low Carbon:

24.5 Suppliers shall use reasonable endeavours to work with Low Carbon to improve sustainability performance (including, but not limited to, obtaining and providing data not currently collected by the Supplier; and considering and implementing reasonable recommendations to improve or mitigate the Supplier’s environmental impact).

24.6 Suppliers shall establish time-bound greenhouse gas emissions reduction targets.

24.7 Suppliers shall implement a plan to achieve the set targets.

24.8 The targets shall cover the material sources of direct and indirect greenhouse gas emissions.

24.9 Continuous efforts shall be made to improve energy efficiency and minimise energy consumption.


Low Carbon expects the highest standards of ethical conduct from Suppliers in all aspects of its business operations. Suppliers shall uphold ethical principles in their relationships, practices, sourcing, and operations.

25. Responsible Sourcing of Materials

25.1 Suppliers shall review all relevant resources and reports which detail the related social risks in relevant supply chains. One example of a relevant resource pertaining to the solar industry is the Responsible and sustainable sourcing of battery raw materials produced by the European Commission. Suppliers shall exercise ongoing due diligence on relevant materials in their supply chains to identify and mitigate risks.

25.2 Due diligence policies and management systems shall be developed to address risks associated with materials originating from high-risk regions.

25.3 Due diligence shall extend down to the material processing level to ensure compliance with relevant standards and mitigate risks related to conflict, child labour, forced labour, human trafficking, human rights violations, health and safety risks, and negative environmental impacts.

25.4 Suppliers shall develop a supply chain traceability protocol, which must show alignment with the high-level principles expressed by the SEIA’s Solar Supply Chain Traceability Protocol or the Solar Stewardship Initiative’s ESG Standard where applicable. The foregoing applies to all technologies (and is not restricted to solar) that include principles of transparency, integration of transparency into management systems, and integration of transparency into operational processes.

25.5 Where applicable, Suppliers shall implement a policy to reasonably ensure that the materials such as (but not restricted to) tantalum, tin, tungsten, cobalt, and gold used in their manufactured products do not provide direct or indirect financing or benefits to armed groups involved in human rights abuses.

25.5.1 Suppliers shall conduct due diligence on the origin and custody chain of these minerals and other potential resources obtained under similar conditions.

25.5.2 Suppliers should be prepared to share their due diligence measures with customers upon request, promoting transparency and accountability.

26. Business Integrity

26.1 Suppliers shall have a zero tolerance policy in place, which aligns with Low Carbon’s Anti-Bribery and Inducements Policy, to prohibit any and all forms of corruption, bribery, extortion, and embezzlement.

27. Disclosure of Information

27.1 Suppliers shall accurately record and disclose information regarding their business activities, labour practices, health and safety measures, and environmental practices.

27.2 Any falsification or misrepresentation of conditions or practices in the supply chain is strictly prohibited.

28. Supplier shall inform Low Carbon (in accordance with paragraph 47) within one week if a breach of this Code is identified or suspected within the Supplier’s value chain or own operations. Low Carbon looks to ensure the alignment of its business operations and project investments with the concept of minimum safeguards, which includes alignment with the UN Global Compact Principles, the UN Guiding Principles for Business and Human Rights, and the OECD Guidelines. As a result, Low Carbon requires all Suppliers to report on their Minimum Safeguards policies, processes, and outcomes on a quarterly and annual basis, as outlined in the reporting template provided by Low Carbon.

29. Low Carbon requires that all Suppliers make reasonable endeavours to respond if invited to do so by the Business and Human Rights Resource Centre’s Company Response Mechanism.

30. Where applicable and as requested by Low Carbon, Suppliers are required to report other SFDR/EUT requirements.

31. Protection of Intellectual Property

31.1 Suppliers shall respect intellectual property rights and safeguard customer information.

31.2 Technology and know-how shall be managed in a manner that protects intellectual property rights.

32. Privacy and Data Protection

32.1 Suppliers shall have processes and practices in place to secure and protect personal data.

32.2 Suppliers shall comply with all privacy, data protection, and cybersecurity laws applicable to Low Carbon and themselves.

33. Information Security

33.1 Suppliers shall implement technical and organisational measures to prevent misuse, compromise, loss, alteration, or unauthorised disclosure of confidential proprietary or protected information.

34. Whistle-blower Protection and Anonymous Complaints

34.1 Suppliers shall provide an anonymous complaint mechanism for managers and workers to report workplace grievances. Such complaint mechanism shall be monitored regularly and approriate actions taken in response to issues raised.

34.2 Whistle-blower confidentiality shall be protected, and retaliation against whistle- blowers shall be strictly prohibited.

34.3 Supplier shall inform Low Carbon, in accordance with paragraph 47 below, of any report or ongoing investigation under this paragraph 34 which impacts Supplier’s provision of goods or services to Low Carbon.

35. Community Engagement

35.1 Suppliers are encouraged to contribute to the social and economic development and sustainability of the communities in which they operate.

Management Systems

Low Carbon believes that sound management systems and commitment are key to enriching the social and environmental wellbeing of our supply chain. Low Carbon holds its suppliers accountable to the above Code of Conduct, and all of its standards. Suppliers shall implement or maintain (as applicable) management systems that facilitate compliance with this Code and all applicable laws, identify and mitigate related operational risks, and facilitate continuous improvement. At minimum, this management system should meet the standards set by ISO9001.

36. Management Accountability and Responsibility

36.1 Suppliers must clearly designate senior executives and company representatives responsible for ensuring the implementation of management systems and associated programs.

36.2 Senior management should regularly review the status of these systems.

37. Legal and Customer Requirements

37.1 Suppliers are required to establish a process to identify, monitor, and understand applicable laws, regulations, and customer requirements, including the requirements outlined in this Code.

38. Risk Assessment and Risk Management

38.1 Suppliers must develop a process to identify risks associated with legal compliance, environmental impact, health and safety, and labour practices.

38.2 The relative significance of each risk should be determined, and appropriate controls, both procedural and physical, should be implemented to mitigate identified risks and ensure regulatory compliance.

39. Improvement Objectives

39.1 Suppliers are expected to set written performance objectives, targets, and implementation plans to enhance their social, environmental, and health and safety performance.

39.2 The supplier shall conduct periodic assessments to evaluate the Supplier's progress in achieving these objectives.

40. Training

40.1 Suppliers should have training programs in place to educate managers and workers on the implementation of company policies, procedures, improvement objectives, and compliance with applicable legal and regulatory requirements.

41. Communication

41.1 Suppliers are responsible for establishing a process to communicate clear and accurate information about their policies, practices, expectations, and performance to workers, suppliers, and customers.

42. Worker Feedback, Participation, and Grievance

42.1 Suppliers must maintain ongoing processes, including an effective grievance mechanism, to assess workers' understanding and obtain feedback on practices and conditions covered by this Code.

42.2 Workers should be provided with a safe environment to voice grievances and provide feedback without fear of reprisal or retaliation.

43. Audits and Assessments

43.1 Suppliers should conduct periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of the Code, and customer contractual obligations related to social and environmental responsibility.

44. Corrective Action Process

44.1 Suppliers must establish a process for promptly addressing and rectifying any deficiencies identified through internal or external assessments, inspections, investigations, and reviews.

45. Documentation and Records

45.1 Suppliers should create and maintain documents and records to ensure regulatory compliance and conformity to company requirements.

45.2 Appropriate confidentiality measures should be implemented to protect privacy.

46. Supplier Responsibility

46.1 Suppliers are expected to communicate the requirements of this Code to their own suppliers and monitor their compliance with the Code.

46.2 Suppliers shall make reasonable efforts to establish traceability of their own supply chains, and maintain open and cooperative collaboration with our efforts to engage with them to continually improve their sustainability performance.

47. Notices

Any notice given by Supplier to Low Carbon in line with this Code shall be delivered by email to the email address set out below. Communication served by email shall be deemed to have been duly given or at the time of transmission.

FAO Justin Thesiger

E-mail: justin.thesiger@lowcarbon.com