Overview
Integrity is one of our Core Values and it guides our associates while conducting the Company’s business and performing our daily activities. TPI operates in multiple regions around the world with different cultural and business norms, yet we follow the highest ethical standards.[1]
Code of Conduct and Anti-Corruption
Our Code of Business Conduct & Ethics (Code) sets the tone regarding ethical behavior and responsible business conduct. The Code covers conflicts of interest, confidentiality, preventing workplace harassment, human rights, and anti-corruption, among other important topics. TPI’s Board, in conjunction with its Audit Committee, is responsible for administering the Code, and has delegated day-to-day responsibility for applying and interpreting the Code to TPI’s Office of the General Counsel. The Code and our separate Foreign Corrupt Practices Act Policy (FCPA Policy) informs associates about the Company’s anti-corruption practices and expressly prohibits direct and indirect payments that violate applicable anti-corruption laws. In 2023, TPI trained its workforce on these critical policies to ensure awareness and to reinforce compliance with our company expectations. Completion of the mandatory compliance trainings are also linked to leadership performance plans. Finally, TPI has also implemented internal compliance mechanisms and processes to ensure alignment with both the UN Global Compact Principles and the Organisation for Economic Co-operation and Development (OECD) guidelines for Multinational Businesses.
Compliance Training
Compliance is an important part of TPI’s commitment to a strong ethical culture. To achieve this commitment, TPI associates receive annual training on subjects that include the Code of Conduct, Diversity & Inclusion, Workplace Harassment, Insider Trading, and Cybersecurity while new associates receive training on these commitments during onboarding.
TPI’s Legal and Compliance teams regularly review and refresh our compliance training needs and requirements to reduce risks associated with TPI’s global operations.
In 2023, we updated our Conflict Minerals, Anti-Bribery/Anti-Corruption, FCPA, and Human Rights policies, as well as our Supplier Code of Conduct, to ensure we are in compliance with all applicable regulations and requirements for TPI and our stakeholders.
Ethics Reporting
TPI strives to create a working environment with the highest ethical standards for our associates. Our Ethics Reporting, Open Door, and Non-Retaliation Policy (Ethics Reporting Policy), outlines numerous avenues to report any policy, legal, compliance, or ethical violations to TPI, including a QR Code and mobile device reporting tool. The Ethics Reporting Policy also encourages contact with the Office of the General Counsel, Board of Directors, or Audit Committee if there is an allegation regarding criminal conduct, violations of local laws, bribery or corruption, or financial statement irregularities. In addition, it describes TPI’s open-door policy and our commitment to non-retaliation against associates that report concerns.
Associates are encouraged to report all concerns either directly or anonymously, through multiple reporting tools including the Ethics Hotline, which is operated by an independent third-party provider. Associates receive ongoing training and communication about how to report concerns, each TPI location displays posters in the local language on ethics reporting, and the Company’s intranet prominently displays reporting tools for associates. Any reports submitted to the Ethics Hotline are only accessible by the Office of the General Counsel and Audit Committee Chairperson to protect the reporter’s identity. All reports regarding a procedural, ethical, or policy concern are taken seriously and investigated promptly 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. To ensure ethics reporting remains effective, we identify trends in reports received and then implement appropriate action plans such as associate trainings.
TPI takes all allegations of misconduct seriously and investigates claims pursuant to the guidance provided in our Investigation Policy. The Investigation Policy seeks to ensure that all investigations are done in a consistent and impartial manner while in compliance with TPI policies and laws in the countries in which we conduct business.
Human Rights
Respect for human rights is embedded throughout the culture at TPI. Human rights protections are included within the Code, our Supplier Code of Conduct, and our Human Rights Policy. Our Human Rights Policy highlights TPI’s explicit respect for internationally recognized human rights as established in the International Bill of Human Rights, the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work, the United Nations Global Compact, the United Nations Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, and the International Labour Organization’s Core Conventions. This includes TPI’s commitment to prohibiting forced and child labor, and to promoting workplace safety, freedom of association and collective bargaining, and IDEA. We also expect our associates, contractors, and suppliers to abide by our Human Rights Policy to ensure respect for human rights in all our business dealings.
Board and Executive Oversight
TPI’s Board represents our most senior governance body for the Company. Nine members currently sit on the Board consisting of 33% female and 33% ethnically diverse members. Members of the Board comprise three committees: (1) the Audit Committee, which oversees fraud prevention and compliance; (2) the Compensation Committee, which oversees director and executive compensation; and (3) the Nominating and Governance Committee (NGC) which oversees sustainability, IDEA, and Board composition. Oversight for our strategies and activities related to sustainability initiatives falls under the responsibilities of the NGC, alongside the leadership team. Our Board delegates responsibility for sustainability to our CEO who manages impacts alongside our senior leadership team.
To help align our compensation and sustainability strategies, we have developed sustainability targets, which are included in our executive compensation plans. These sustainability targets include safety enhancement and waste reduction goals.
Enterprise Risk Management
TPI uses an Enterprise Risk Management (ERM) framework to help identify and evaluate risks, including sustainability-related risks such as those identified in TPI’s Task Force on Climate Related Financial Disclosures (TCFD) located on pages 52-53. Identified risks may threaten the achievement of our strategic business objectives.
Many of these risks are quantifiable and controllable, but others are external and difficult to predict (e.g., geopolitical uncertainty, global market conditions). Many of our strategic business objectives are centered around traditional business goals such as revenue and profitability but given the nature of our Company in the renewable energy sector, it is imperative we continue to lead and set the “Sustainability Gold Standard.”
We prioritize our top enterprise risks and develop comprehensive action plans to mitigate potential impacts to our organization. The status of our action plans is monitored regularly by our senior leadership team and is reviewed, at least annually, by our Board.
External Certifications
We have implemented management systems at our eleven manufacturing facilities according to the international standards for quality, environment, and health and safety, ISO 9001, ISO 14001, and ISO 45001, respectively. We perform internal audits and have annual third-party surveillance audits performed to maintain our certifications as well as ensure regulatory compliance.
Furthermore, both of our facilities in Türkiye have obtained ISO 50001 (Energy Management), ISO 14046 (Water Footprint), ISO 14064 (Greenhouse Gases), and ISO 27001 (Information Security) certifications. Our automotive facilities in Rhode Island and Juarez, along with our corporate headquarters, have achieved certification for IATF 16949 (Quality). Rhode Island also obtained ISO/IEC 17025 (Testing Calibration) certification. Additionally, our Field Service Spain entity received ISO 9001, ISO 14001, and ISO 45001 certifications for the first time this year. Our certifications can be found on our website.[2]
Moreover, 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, in accordance with industry standards and TPI’s customers’ requirements. To ensure compliance, we audit our largest global raw material suppliers to ensure consistency and standardization throughout the value chain; please see section 6 below for more information.
Information Security
We are committed to safeguarding our critical information assets and data and have implemented a defense-in-depth strategy based upon the NIST Cybersecurity Framework. We conduct annual risk assessments to identify and evaluate information security risks and develop and implement mitigation strategies to proactively respond to these risks. We also undergo an annual cyber security audit conducted by a reputable external agency, reinforcing our commitment to maintaining robust cyber security measures. We believe all of our associates are responsible for ensuring a robust information security program; therefore, we provide onboarding as well as annual refresher information security training to our associates. Information security updates are provided regularly to our senior leadership team and are communicated to our Board of Directors, via the Audit Committee, quarterly.
[1] Committee of Sponsoring Organizations (COSO): Internal Control – Integrated Framework (2013), https://www.coso.org/internal-control