ESG Supplier Vetting Policy

1. Purpose

HDM Solar is dedicated to responsible, ethical, and sustainable sourcing throughout our global supply chain. As a UK-based solar and renewables distributor, we recognise our responsibility to ensure that all products imported under the HDM brand align with the values of transparency, environmental stewardship, and respect for human rights.
This ESG policy defines the minimum environmental, social, and governance standards expected of all manufacturing partners. It is used during on-site assessments, supplier audits, and factory visits, including facilities across China and other key solar-manufacturing regions.

2. Scope

This policy applies to all suppliers involved in the production, assembly, or distribution of HDM Solar products. This includes contractors, subcontractors, and upstream raw-material sources such as polysilicon, ingots, wafers, solar cells, frames, junction boxes, and modules. All suppliers must ensure these standards are cascaded throughout their own supply chains.

3. Environmental Standards

3.1 Energy, Emissions and Resource Efficiency

Suppliers must:

  • Measure and actively reduce carbon emissions across operations.
  • Demonstrate energy-efficiency initiatives (LED lighting, efficient motors, heat recovery, etc.).
  • Track electricity consumption and disclose renewable energy usage.
  • Manage water responsibly, including recycling where feasible.
  • Minimise environmental impact associated with high-energy manufacturing processes (e.g., polysilicon purification, ingot casting).

3.2 Materials and Chemical Management

  • Maintain clear documentation on hazardous chemicals and proper handling/storage procedures.
  • Ensure waste chemicals, solvents, and by-products are disposed of through licensed and accredited facilities.
  • Provide Material Safety Data Sheets (MSDS) on request.
  • Avoid banned substances listed in relevant UK/EU regulations (e.g., REACH, RoHS).

3.3 Waste Management and Recycling

  • Segregate, label, and manage waste streams (glass, aluminium, unused cells, EVA plastics, pallets & packaging).
  • Operate recycling and circular-economy practices wherever possible.
  • Reduce single-use plastics and unnecessary packaging, especially for export shipments.


4. Social Standards

4.1 Labour Practices

Suppliers must ensure:

  • No forced labour, bonded labour, prison labour, or involuntary coercive work of any kind.
  • No child labour, with formal age verification and compliance with local and international laws.
  • Safe and fair working conditions, including adequate ventilation, lighting, PPE, and sanitation.
  • Employees receive written contracts, fair wages, legally compliant working hours, and overtime compensation.
  • Zero discrimination based on gender, ethnicity, religion, or migration status.

4.2 Worker Wellbeing and Rights

Suppliers must ensure:

  • Workers have the right to raise complaints safely and anonymously, and without fear of retaliation.
  • Health and safety training is documented and carried out regularly.
  • Emergency exits and routes remain unobstructed, clearly marked, and included in scheduled fire / evacuation drills.
  • Canteen facilities (where offered) meet basic health and safety standards.

4.3 Ethical Recruitment

Suppliers must ensure:

  • No recruitment fees are charged to workers at any stage of employment.
  • Use of credible labour agencies with verified practices.

5. Governance and Compliance

5.1 Transparency

Suppliers must:

  • Provide full transparency of factory ownership, facility locations, and subcontractors.
  • Share relevant certification and audit reports where available (SA8000- Social Accountability Standard, ISO 9001 – Quality Management Systems, ISO 14001 - Environmental Management Systems, ISO 45001 - Occupational Health & Safety Management, RBA - Responsible Business Alliance, etc.).
  • Allow unannounced site visits and cooperate with HDM Solar representatives and third-party auditors.
  • Notify HDM Solar of any significant changes in operations, ownership, or supply chain structure.

5.2 Traceability

Suppliers must:

  • Maintain traceability systems for raw materials, including polysilicon sourcing (country, facility, batch if possible).
  • Implement procedures ensuring products are free from forced labour and comply with international import regulations (e.g., UK Modern Slavery Act)

5.3 Anti-Corruption and Business Ethics

Suppliers must follow:

  • Zero-tolerance policy for bribery, informal “facilitation payments,” or improper gifts.
  • Accurate record-keeping and honest reporting.
  • Protect all HDM Solar intellectual property, confidential information, and commercial data.

6. Performance Evaluation and Corrective Actions

HDM Solar uses the following evaluation outcomes:

  • Compliant: Supplier meets expectations; approved for continued business.
  • Conditional: Minor gaps requiring corrective actions within a defined timeline.
  • Non-Compliant: Major ESG risks (e.g., forced labour indicators, hazardous practices, traceability issues). May result in suspension or termination of cooperation.

Suppliers must submit written corrective action plans (CAPs) when required and demonstrate measurable improvements. HDM Solar reserves the right to reduce business volume, pause orders, or withdraw approval based on ESG-related performance.

7. Supplier Acknowledgment

All suppliers must formally acknowledge this policy, demonstrate ongoing compliance, and support transparent ESG engagement across the supply chain. HDM Solar expects continuous improvement and proactive communication from all partners.

A. Modern Slavery and Forced Labour Addendum

HDM Solar maintains a zero-tolerance stance on forced labour across all tiers of the supply chain. Suppliers must provide evidence that their operations, and those of their upstream partners, are free from coercion, intimidation, debt bondage, or state-imposed labour.

Requirements include:

  • Documented verification of labour conditions for all workers, including migrant and agency labour.
  • Clear due diligence on polysilicon and raw-material sourcing, with declarations confirming no ties to forced labour practices.
  • Immediate notification to HDM Solar if any forced labour risks or allegations arise within the supplier’s supply chain.
  • Cooperation with HDM Solar–initiated investigations, audits, or third-party assessments relating to labour concerns.

Failure to comply may result in immediate suspension of business.

B. Zero-Tolerance Indicators

  • Forced or state-imposed labour.
  • Child labour or falsification of age documents.
  • Concealment of subcontracting without prior disclosure.
  • Deliberate obstruction of audits or falsification of records.
  • Illegal dumping of hazardous waste or severe environmental violations.
  • Bribery, facilitation payments, or attempts to influence HDM Solar representatives inappropriately.

Suppliers must ensure that these red-flag behaviours are actively monitored and prevented.