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, anti-bribery and anti-corruptions expectations, and many 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 ensuring compliance 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-bribery and anti-corruption practices and expressly prohibits direct or indirect payments that violate applicable laws. TPI has also implemented internal compliance mechanisms and processes to ensure alignment with both the UN Global Compact Principles and the Organization for Economic Co-operation and Development (OECD) guidelines for Multinational Businesses. In 2024, TPI trained its workforce on these critical policies to ensure awareness and reinforce compliance with our company expectations. Completion of the mandatory compliance trainings are also linked to leadership performance plans.
Compliance is an important part of TPI’s commitment to a strong ethical culture. 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 additional compliance training during onboarding. TPI’s Legal team regularly review and refresh our compliance training needs and requirements to reduce risks associated with TPI’s global operations. In addition, TPI reviews company policies on an annual basis to ensure we remain in compliance with all applicable regulations and requirements both for TPI and our stakeholders.
This year, TPI also retained a third-party to assess the effectiveness of our compliance program. The findings from the third-party highlighted TPI’s strong culture of integrity and transparency, effective policies, procedures, and controls, and impactful measures to prevent, detect, and respond to compliance violations.
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 policy, legal, compliance, or ethical violations to TPI. The Ethics Reporting Policy also encourages contact with the
Office of 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, the policy describes TPI’s 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, including a QR Code and mobile device reporting tool. Any reports submitted to the Ethics Hotline are only accessible by the Office of the General Counsel and Audit Committee Chair 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 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.
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. Additionally, TPI’s Supplier Code of Conduct and Human Rights Policy addresses protections for associates’ safety at work, freedom of association, collective bargaining, and Inclusion, Diversity, Equity, and Awareness (IDEA) principles. 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 and TPI ensures the policy is communicated to all external stakeholders.
TPI recognizes that a sustainable business extends beyond environmental and social dimensions to include robust digital resilience. Our cybersecurity program is a foundational element of this commitment, working to protect the integrity, confidentiality, and availability of our digital assets while fostering trust among our associates, customers, suppliers, owners, and other stakeholders.
Our approach to cybersecurity is guided by leading industry practices and standards, principally the National Institute of Standards and Technology (NIST) Cybersecurity Framework 2.0. This provides a structured approach spanning governance, risk identification, protection measures, detection capabilities, response readiness, and recovery protocols. The framework is applied consistently across our global operations, covering enterprise systems, operational technology, shared services, and supply chains to help create a resilient and adaptable security posture.
Governance is central to our cybersecurity strategy. The program is led by our Chief Information Security Officer (CISO) and remains integral to the organization’s broader sustainability commitments. A management-level Risk Committee provides ongoing direction, and IT and cyber risks are maintained in our enterprise risk register with defined owners and measurable indicators tracked over time. Independent assessments are performed annually, including penetration testing, tabletop exercises facilitated by an external firm, and an assessment of the program against the NIST Cybersecurity Framework. A multi-layered, risk-based defense strategy combines proactive threat identification, vulnerability management, and incident response planning, and security review is embedded in our solution architecture process so that technologies are evaluated before they are acquired and deployed.
The human element is a critical component of our cybersecurity framework and prevention efforts. We conduct annual cybersecurity training programs to enhance associates’ awareness of cyber risks and their critical role in protecting the integrity, confidentiality, and availability of our digital assets. These mandatory sessions reinforce our data handling obligations along with accuracy and confidentiality practices, while periodic assessments help keep our practices aligned with evolving privacy laws. Periodic phishing simulations and targeted training sessions equip our workforce to recognize and respond to threats effectively. Through these initiatives, we cultivate a culture of vigilance and shared responsibility for digital security.
Our data protection framework is supported by security technologies and by engagements with trusted third-party experts that strengthen our risk management and reinforce the mechanisms through which we manage data access requests. By applying least privilege access, we limit individuals to the data necessary for their roles, supporting transparency and safeguarding individual privacy rights.
Through these cybersecurity measures, we not only protect our operations and digital assets but also strengthen our capacity for sustainable growth and innovation in an increasingly digital landscape. This commitment supports the resilience and trust essential to achieving our long-term vision for sustainability.
TPI’s Board represents our most senior governance body. Our Board of Directors reflects a diverse mix of backgrounds, experiences, and perspectives. Members of the Board comprise three committees:
(1) Audit Committee, which oversees fraud prevention and compliance; and (2) Compensation Committee, which oversees director and executive compensation; both Committees oversee sustainability and IDEA. 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 strategy 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, IDEA, and waste reduction goals which can be found in TPI’s Proxy Statement.
TPI Employs an Enterprise Risk Management (ERM) framework and process to help identify, assess, mitigate and monitor risks, including sustainability-related risks. While many risks are measurable and controllable, others – such as geopolitical instability and global market volatility – are external and inherently unpredictable. Our strategic objectives include traditional priorities like revenue growth and profitability. However, as a renewable energy leader, we are steadfast in our commitment to setting the “Sustainability Gold Standard.”
We focus on our most critical enterprise risks and have implemented detailed action plans to mitigate their potential impact. Progress on these plans is reviewed regularly by our senior leadership team and reviewed by our Board of Directors at least annually.
We have implemented management systems at our four manufacturing facilities according to the international standards for quality, environment, and health and safety, ISO9001, ISO14001, and ISO45001, respectively. We perform internal audits and have annual third-party surveillance audits performed to maintain our certifications as well as ensure regulatory compliance.
One of our facilities in Juarez achieved IATF 16949 (Quality). Furthermore, our Field Service entity in Spain received ISO9001, ISO14001, and ISO45001 certifications. Our certifications can be found on our website.
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 ISO9001, 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 7 or Sustainability Report for more information.
