Overview

To help ensure we follow all laws and regulations where we do business, we have developed and implemented practices to promote a culture of compliance throughout our organization. We are committed to global integrity. Although everyone has a general understanding of integrity - do the right thing, even when no one is watching - applying this general concept to our day-to-day operations at TPI can be complicated. Our associates operate in multiple regions around the world with different cultural and business norms. To help ensure we follow all laws and regulations where we do business, we have developed and implemented practices to promote a culture of compliance throughout our organization.

Board and Executive Oversight

TPI’s Board of Directors is the highest governance body within the company. Members of the Board comprise the Audit Committee, which oversees fraud prevention and compliance, and Compensation Committee and the Nominating and Corporate Governance (NCG) Committee, both of which oversee diversity and board composition. The NCG Committee oversees and reviews all ESG strategies and activities, alongside TPI’s senior leadership. To help align our compensation and ESG strategies, we have developed ESG metrics, which are included in our executive compensation plans. We include safety metrics, and we may add additional ESG components in the future.

Code of Conduct

Our Code of Business Conduct & Ethics (Code) sets a tone at the top for the entire company regarding ethical behavior. The Code covers the topics of conflicts of interest, confidentiality, preventing workplace harassment, and anti-corruption, among others. TPI’s Board of Directors, in conjunction with its Audit Committee, is responsible for administering the Code, and has delegated day-to-day responsibility for administering and interpreting the Code to TPI’s General Counsel who serves as TPI’s Compliance Officer. The Code and our separate Anti-Corruption Policy educate associates on anti-corruption practices and expressly prohibits direct and indirect payments that violate applicable anti-corruption laws. TPI’s associates receive annual training on both the Code and the Anti-Corruption Policy and are available in their local language.

Ethics Reporting

As part of the Code training, associates are encouraged to raise any ethical concerns either directly or anonymously. They can report concerns anonymously through a hotline that is operated by a third-party provider. Any messages submitted to the hotline are only accessible by the Company’s Compliance Officer and Audit Committee Chairperson, who then decide if the concern will be investigated by the human resources department, the internal audit department, the internal legal department or an external law firm, depending on the nature of the concern. We do not retaliate against any associate who reports ethical concerns in good faith. Posters regarding the anonymous hotline are posted at all our manufacturing facilities in the local language.

Third-Party Due Diligence

We have implemented policies and procedures to help us evaluate the integrity of our third-party business partners. TPI has documented standards for suppliers and monitors performance throughout the supplier lifecycle. We do this by using an independent vendor assessment tool, conduct audits of our suppliers, and require suppliers to complete an annual questionnaire that identifies compliance and policies from these companies for areas such as child labor, corruption and safety.

External Certification

We have implemented Management Systems at several of our locations according to the international standards for quality, environment, and health and safety—ISO 9001, ISO 14001, and ISO 45001, respectively. We audit our top global raw material suppliers to these standards as well. The International Organization for Standardization (ISO) develops and publishes international standards for various topics and management systems. ISO standards provide guidance and requirements on how to implement best practices for each topic. Once a company has implemented the appropriate practices, they can go through an external certification process. As of the date of this report, we have ten facilities ISO 9001 certified, six facilities ISO 14001 certified, and four facilities ISO 45001 certified. We have a roadmap to have the remaining facilities certified by the end of 2021. Our current certifications are found on our website. We require our top global raw material suppliers to maintain a Quality Management System (QMS), Quality Assurance (QA) or Product Quality plan compliant with ISO 9001 requirements, in accordance with industry standards, and meeting TPI’s customer requirements.