How We’ve Committed to Ensuring No Forced Labor Ever Touches our Projects 

How We’ve Committed to Ensuring No Forced Labor Ever Touches our Projects 

Company News |
By Dan Diamond

At Sol Systems, we are committed to a just equitable energy transition and to ensuring this commitment flows through our entire business. In the past year, the production of polysilicon has been linked in many ways to forced labor in the Xinjiang region of China. Sol Systems is taking steps to ensure our solar projects are free of products produced with forced labor and we have signed onto industry-wide commitments to ensure we all work towards and commit to this goal together.  

Companies like Sol Systems, that acquire, develop, finance, build, own and operate PV projects, and that both procure modules and contract with companies that procure modules, have a responsibility to their customers to ensure that the procurement and installation of solar modules is done responsibly and without unintended negative consequences. This means that we must tackle this issue systemically and through policies and procedures that ensure we are not contributing to the human rights abuses occurring in the Xinjiang region or any other region.  

The American solar industry is strongly united in this mission, and Sol Systems was proud to help develop the Solar Energy Industries Association (“SEIA”) Solar Industry Forced Labor Prevention Pledge, of which it was a founding signatory. Along with the Pledge, Sol Systems developed and implemented a procurement strategy for modules for both direct procurement for issuance to EPC Contractors for utility-scale projects, and indirect procurement for distributed generation (DG) projects through EPC Contractors.   

In development of our procurement strategy, we surveyed the leading module manufacturers to ensure we understand the market supply, dynamics, and constraints. We learned about the module manufacturers’ allied approach to ensure the commitment to avoid all exposure to products that are in any way sourced from the Xinjiang region, due to forced labor concerns. Manufacturers supplying the US market are tracking the complete supply chain from polysilicon production, to ingots, wafers, cells, and modules.  

The module manufacturers supplying the US and EU markets are all aware of and actively reacting to the market demands for forced-labor free products, and they all have implemented supply chain execution plans to address this. To proactively facilitate these manufacturer’s commitments, Sol is working with SEIA to apply the recently issued Traceability Protocol and Buyer’s Guide that establishes guidelines for traceability protocols and documentation, supply chain security, enforcement, and auditing. We also intend to incorporate specific provisions in our Module Supply Agreements (MSA) that contractually prohibits any part of the supply chain from being sourced from the Xinjiang region. These restrictions include products from specific suppliers, the Xinjiang region generally, and any other country or region known or supposed to use forced labor. This restriction is passed through to their suppliers, and they are required to declare their supply chain origins.  

These measures will help us ensure our work in the solar industry reflects the collective goal of the solar industry to catalyze positive change and fight climate inequities.  

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