Wuxi Suntech PV Modules - Technical Review

Desktop Review and Factory Audit

Wuxi Suntech Power Co., Ltd.

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Wuxi Suntech PV Modules - Technical Review

Issue and Revision Record

Revision Date Originator Checker Approver Narrative 1.0 08/07/2014 JF/GS/RR CM/MG OS Draft 1.1 25/07/2014 JF/GS CM OS Draft – updated following comments 2.0 17/10/2014 JF/GS AK BR Final

Disclaimer

This document has been prepared for the titled project or named part thereof and should not be relied upon or used for any other project without an independent check being carried out as to its suitability and prior written authority of OST Energy being obtained. OST Energy accepts no responsibility or liability for the consequence of this document being used for a purpose other than the purposes for which it was commissioned. Any person using or relying on the document for such other purpose agrees, and will by such use or reliance be taken to confirm his agreement to indemnify OST Energy for all loss or damage resulting therefrom. OST Energy accepts no responsibility or liability for this document to any party other than the person by whom it was commissioned.

To the extent that this report is based on information supplied by other parties, OST Energy accepts no liability for any loss or damage suffered by the client, whether contractual or tortious, stemming from any conclusions based on data supplied by parties other than OST Energy and used by OST Energy in preparing this report.

Awards and Recognitions

ACQ Magazine Finance Monthly Magazine UK Technical Advisor of the Year UK Renewables Advisory Firm of the Year 2013 & 2012 2010

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Contents Glossary ...... 1 Executive Summary ...... 2 Overview of the company ...... 2 Technical review of PV modules ...... 3 Independent module testing ...... 3 Review of production machinery and key components...... 4 Factory visit findings ...... 4 Acceptance in the marketplace ...... 6 Operational performance ...... 6 R&D ...... 6 Warranties ...... 6 Product Liability Insurance ...... 7 Environmental, Health and Safety Review ...... 8 1 Introduction...... 10 2 Company Overview ...... 11 2.1 Shunfeng Photovoltaic International ...... 11 2.2 Wuxi Suntech Power Co., Ltd ...... 11 2.2.1 Manufacturing capabilities ...... 12 2.3 Quality management system ...... 13 3 Technical Review of Suntech PV Modules ...... 15 3.1 Module technical characteristics ...... 15 3.2 Low irradiance performance ...... 15 3.3 Module efficiency ...... 16 3.3.1 Manufacturer comparison ...... 17 3.3.2 OST comments ...... 21 3.4 Fill Factor ...... 21 3.4.1 Manufacturer comparison ...... 21 3.4.2 OST Comments ...... 25 3.5 Conclusions on manufacturers comparison ...... 25 3.6 Certifications ...... 25 3.7 Returns ...... 26 4 Module Testing ...... 29 4.1 The set of validation tests ...... 29 4.1.1 Visual inspection ...... 30 4.1.2 Maximum Power measurement ...... 30 4.1.3 Electroluminescence imaging ...... 31 4.1.4 Insulation test ...... 31

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4.1.5 Performance at NOCT ...... 31 4.1.6 Performance at low and intermediate irradiance ...... 32 4.1.7 Thermal imaging & ΔT ...... 33 4.1.8 Hot spot endurance test ...... 33 4.1.9 Potential Induced Degradation test ...... 33 4.1.10 Conclusions ...... 34 5 Review of Production Machines and Key Components ...... 35 5.1 Suppliers of production machines ...... 35 5.2 Suppliers of materials and key components ...... 44 6 Factory Visit Findings ...... 60 6.1 Receipt of material from supplier ...... 60 6.1.1 Polycrystalline cells characteristics ...... 70 6.2 Components storage ...... 70 6.3 Module manufacturing process ...... 72 6.3.1 Quality inspection during production ...... 73 6.3.2 Traceability ...... 73 6.3.3 Material preparation ...... 74 6.3.4 Back sheet and EVA preparation ...... 78 6.3.5 Cell tabbing/soldering and stringing ...... 78 6.3.6 Soldering, EVA and back sheet lay-up ...... 83 6.3.7 Lamination ...... 89 6.3.8 Framing and junction box assembly ...... 92 6.3.9 Module cleaning and testing ...... 94 6.3.10 Final inspection ...... 97 6.3.11 Packaging...... 99 6.4 Test facilities at Suntech ...... 101 6.5 Training ...... 101 7 Acceptance in the Marketplace ...... 103 7.1 Project experience ...... 103 7.2 Bankability ...... 104 7.3 Contractors and Developers ...... 105 8 Operational Performance ...... 107 9 R&D ...... 108 10 Warranties and Guarantees ...... 109 10.1 Limited warranty for PV modules ...... 109 10.1.1 Limited product warranty ...... 109 10.1.2 Limited peak power warranty ...... 109 10.1.3 Warranty exclusions and limitations ...... 110 10.1.4 Claims ...... 110 10.1.5 Various ...... 111 10.2 Warranties and guarantees comparison ...... 111 10.3 Third party insurance...... 113 10.4 Product Liability Insurance ...... 113 10.4.1 Chubb Insurance (China) Company Limited ...... 113

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10.4.2 Yingda Taihe Property Insurance ...... 114 11 Environmental, Health and Safety Review ...... 115 11.1 International Lender EHS Guidelines ...... 115 11.1.1 IFC/World Bank ...... 116 11.1.2 Equator Principles ...... 117 11.1.3 EBRD E&S Standards and Guidelines ...... 118 11.2 Suntech’s EHS Management ...... 118 11.2.1 Assessment and Management of Environmental and Social Risks and Impacts119 11.2.2 Labour and Working Conditions ...... 119 11.2.3 Resource Efficiency and Pollution Prevention ...... 120 11.2.4 Community Health, Safety, and Security ...... 121 11.2.5 Biodiversity Conservation and Sustainable Management of Living Natural Resources ...... 121 11.3 Conclusion ...... 121

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Glossary Table 1: Abbreviations Abbreviation Meaning AC Alternating Current pc-Si Poly-crystalline Silicon CPVT National Center of Supervision & Inspection on Solar Photovoltaic Products Quality DC Direct Current DUT Device under test EL Electro Luminescence EU European Union EVA Ethylene-Vinyl Acetate FF Fill Factor FPC Factory Production Certificates IEC International Electrotechnical Commission ISO International Organization for Standardization IV (I) Current (V) Voltage JB Junction Box Kpcs 1000 pieces LID Light Induced Degradation MCS Microgeneration Certification Scheme NOCT Nominal Operating Cell Temperature OHSAS Occupational Health and Safety Assessment Series pcs Process Control System PID Potential Induced Degradation PR Performance Ratio PV Photo-Voltaic R&D Research and Development STC Standard Test Conditions VDE Verband Deutscher Elektrotechniker

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Executive Summary

OST Energy has been appointed by Wuxi Suntech Power Co., Ltd. (‘Suntech’ or ‘the Manufacturer’) to undertake an independent technical review of three models of its poly- crystalline silicon photovoltaic (PV) modules.

This review has been undertaken based on information provided via email, discussions with Suntech staff, independent testing, industry knowledge, a factory visit and information available in the public domain. While every effort has been made to verify source information, OST takes no responsibility for the completeness or otherwise of the information provided for the purpose of the review.

Overview of the company

Wuxi Suntech Power Co. Ltd. specialises in the production and sale of mono-crystalline and polycrystalline silicon PV modules. Suntech was founded in 2001 as a subsidiary of Suntech Power Holding. Co., Ltd.

Suntech, as a subsidiary of Suntech Power was a leading supplier of solar modules in 2011 and has supplied more than 8 GW of modules to more than a thousand customers in more than 80 countries. Suntech also manufactures solar cells at Wuxi, with a production capacity of 2.1GW. The modules under review and all other modules produced at Wuxi are produced under the Wuxi Suntech brand.

On the 7th of April 2014, Suntech, the main PV module manufacturing facility of Suntech Power Holding became a full subsidiary of Shunfeng Photovoltaic International. Shunfeng Photovoltaic International focuses on the research and development, manufacturing and sales of wafers, solar cells and solar modules. The Shunfeng Group is the largest independent private solar provider of solar energy in China and has reportedly delivered 890 MW in 2013.

With the recent acquisition of Suntech by Shunfeng Group, the Group plans to quadruple the generation capacity at Wuxi.

Wuxi Suntech Co. Ltd is based in Wuxi, Jiangsu in China. The Manufacturer employs approximately 4,700 people worldwide, involved in the production of mono-crystalline and polycrystalline PV cells and modules, sales and distribution. The current peak production capacity in Chinese sites is 2.5 GW per year.

Suntech is a member of the PV CYCLE association for the European Market and we have sighted the certification. Suntech also holds the following international certifications issued by SGS S.A.  ISO 9001:2008 - Quality Management Systems (expires on 16th August 2015)  ISO 14001:2004 - Environmental Management Systems (expires on 5th August 2015)  OHSAS 18001 - Health and Safety Management Systems (expires on 1st September 2016)  SA 8000:2008 - Social Accountability International (SAI) (expires on 10th September 2016)

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Technical review of PV modules

This report has focused on three polycrystalline silicon module models manufactured by Suntech at the Wuxi manufacturing facility:  STP250-20/Wd  STP255-20/Wd  STP300-24/Ve

Suntech modules hold a range of certifications which we consider to be in-line with market standards and appropriate for use in the EU and UK.

According to the results of the independent low irradiance performance test performed by IPSol on the STP255-20/Wd modules, the profiles of the low irradiance curves of the modules tested by IPSol are in line with our expectations. The Manufacturer has provided low irradiance data on samples of the two other modules under review which indicate low irradiance relative efficiency to be in line with our expectations.

The module efficiencies and fill factors at STC and NOCT have been compared to a range of other poly-crystalline modules with the same nominal power sold in the PV market and produced by top-tier and reputable manufacturers. We note that all Suntech modules reviewed show STC efficiencies slightly above average. The modules also showed above average NOCT efficiencies by market standards.

The Suntech modules under review all have fill factors above industry standards for polycrystalline modules at both STC and NOCT, while the fill factors of the STP2555-20/Wd module ranked above average market offering. Suntech modules all have fill factors greater than 0.7 which indicates that the cells utilised by Suntech are of satisfactory quality

The positive power tolerance of 0/+5% of the modules results in effective tolerance values of up to 12.5W, 12.75W and 15W for the three modules under review which we consider to be above market standards.

Independent module testing

As part of our review, a set of validation tests were carried out on a set of 11 modules (model STP255-20/Wd), selected by OST Energy, at IPSol Energy laboratories in Nottingham. The tests and measurements made by IPSol were intended to probe the reliability and manufacturing quality of the modules and also to assess their performance. The set of validation tests occurred during May/June 2014 and the following tests were undertaken to assess the modules’ quality and reliability:  Visual inspection  Maximum power measurement  Electroluminescence testing  Insulation testing  Performance at NOCT  Performance at low and intermediate Irradiances  Thermal Imaging/∆T  Hot-spot endurance test  Potential induced degradation test

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All modules tested were generally of a high quality, with power outputs across a range of conditions meeting or exceeding the manufacturer’s quoted values. There was a narrow spread in the results for the five modules that underwent performance testing suggesting a consistent quality of module across the sample. Resistance to hotspot stressing was excellent, and though PID stressing caused a small drop in power output, the results remained comfortably within the IPSol ‘A’ classification for PID resistance.

The EL and thermal imaging showed the cells of the modules to be well matched and of a satisfactory quality.

While the test results are promising we do not consider it possible to draw any profound conclusions regarding the population the samples were taken from.

Review of production machinery and key components

Module production is undertaken at the Wuxi Suntech facilities with machines from a number of suppliers. We note that limited information was available for some of the manufacturers. We recommend that further information is provided on the unknown manufacturers.

Materials and key components are sourced from suppliers majorly from Asia and from various countries worldwide.

OST notes that all the modules reviewed have common suppliers and production machines. All of the key components are certificated by VDE Prüf- und Zertifizierungsinstitut. Any additional components used or intended to be used in the manufacturing of the Suntech modules should be added to the CDF outlined in the VDE Prüf- und Zertifizierungsinstitut list.

Poly-crystalline cells are provided internally by Suntech and by other suppliers. The cells provided by Suntech, are listed in the VDE certificate. Separate certification for component suppliers have been listed in ‘The Review of Production Machinery and Key Components’.

Factory visit findings

The module production facilities in Wuxi were visited on the 12th June 2014 by Martin Cincelli and Gustaf Schuler of OST Energy and Tim Carter of IPSol Energy. We can confirm that the facility was in line with expectations of a satisfactory market standard.

The factory consists of five separate buildings, two containing the production lines, two warehouses and one office building. Protective equipment is worn by all staff throughout the factory, including Suntech uniform consisting of trousers, shirt and hat, gloves and shoes. Visitors are given hair and shoe protectors before entering the workshops which is in line with good practice.

Incoming checks are undertaken on receipt of the materials from the suppliers. Components which pass the incoming checks are labelled with a green barcode (PV cells) or a stamp (all other components) and the serial number is recorded in the SAP warehouse management system. The system allows for traceability of the components in the storage warehouses before entering the production lines where a Manufacturing Execution System (MES) is used. We consider the implementation of the MES and SAP systems used at Suntech to offer a reliable method for traceability of the components and products.

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The temperature and relative humidity in the warehouse where the EVA and back sheet components are stored and prepared for production are controlled according to the specifications of the manufacturers; however, more frequent controls and an automatic alarm if the parameters exceed the limits would be desirable.

The production at the factory is fully automated with several production lines consisting of 48 tabbing and stringing machines, 92 laminators, 53 framing machines and several EL and flash testing machines.

We have been provided with the quality control plan for each of the processes and we consider the quality control to be in line with our expectations with minor comments included in the body of our report.

Visual checks are undertaken on 100% of the cells after tabbing and stringing on the lay-up station before lamination; in addition a visual inspection is carried out immediately before the modules undergo EL testing and prior to packaging. We note that no visual checks are performed on the front of the module prior to lamination. We consider visual checks on the module from both sides as market standard and recommend to extend the range of visual checks at this stage.

According to Suntech, certain tests such as a pull test between EVA and the glass, the silicone filling of the junction box for the adhesion between junction box and back sheet and appearance test are performed regularly; however, are not included in the Lamination - Quality Control Plan. We consider the tests performed at this stage as stated by Suntech as satisfactory; however, we note that these tests and their quality criteria should be added to the QCP.

Electroluminescence (EL) testing is undertaken on most of the modules, prior to lamination and on all modules post-lamination. Suntech confirmed that from July 2014 all modules are EL tested prior to lamination. We have been provided with the pass / fail criteria for the EL testing which we consider to be in line with our usual market expectations. We have been advised by Suntech staff that all personnel in charge of EL testing are trained by a trainer at the machine and subsequently undergo an examination before being capable of operating independently. In order to maintain the required level of competency, an annual retraining program, incorporating an examination of knowledge and skills is to be carried out, which we consider good practice.

Each module undergoes a final inspection following testing. The list of checks is comprehensive; and during our visit we did not witness any modules being rejected during these final visual checks. We note that during our visit the average final inspection time per module was between 5 and 10s and we do not consider that all quality controls can be achieved in this time.

The QCP requirements for packaging could be better defined in the QCP as we consider the level of detail of the information provided will not inform the operator on the level of accuracy required. However, Suntech stated that a detailed inspection document is issued in their IBMS for packaging which includes the inspection items, inspection frequency, inspection tool, and judgment criteria. Additionally all responsible staff is trained on the job and informed about the quality requirements of packaging. OST has not been provided with this document for review and as such we cannot comment on the suitability of the inspection terms.

A test facility exists at the Suntech production facility in Wuxi to undertake tests equivalent to IEC61215 and IEC61730 standards. We note that not all manufacturers can offer this thorough in-house testing and thus this is a positive indication of their QA processes.

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Acceptance in the marketplace

We have been provided with a list of projects utilising Suntech modules in Europe, USA and other countries. We consider that the list of projects is indicative of acceptance within the European and global marketplace; however, we note that the list does not contain projects executed in the UK.

Suntech has also provided a list of banks and financial institutions involved in the financing of projects utilising Suntech modules and EPC contractors that have used Suntech modules. We consider the list of EPCs indicative of a good level of general acceptance; however, the list of banks/financial institutions is indicative of bankability only in a few European countries.

Operational performance

OST has not been provided with operational data to enable a detailed analysis of the performance of the reviewed Suntech modules; Suntech provided a summarized operational data and final performance ratio of a plant where Suntech STP250-20/Wd modules similar to the models under review, are installed.

The PR data suggests acceptable performance for this specific plant that uses Suntech modules, but we note that the performance data of the plant is a result of the performance of different systems. Although modules largely contribute to the final performance, in the absence of DC tests, and more detailed operational data, we can only acknowledge that the plant has been operating above expectations.

R&D

Suntech has provided a spread sheet outlining their recent research projects between 2011 and 2013. No specific documentation on the R&D activities of Suntech has been provided, however we understand that Suntech is engaged with a leading institution for silicon solar research in New South Wales, in Australia. Suntech and the University of New South Wales jointly-developed PERL cell technology, which set the 2009 world record for solar conversion efficiency. The PERL cell technology is now employed on all Suntech Pluto cells and Hi-Performa modules.

Warranties

Suntech Power has provided two warranty documents; one that applies globally and a second that applies only inside the European Economic Area and Switzerland. OST has reviewed the warranty documentation which applies in Europe, entitled ‘2014 Suntech standard warranty - Europe’.

The Manufacturer provides two types of warranties to its customers:  10 year limited product warranty  25 year limited peak power warranty

Suntech warrants, as a voluntary, independent performance warranty, that each PV module will exhibit a power output of no less than:  97% of nominal power (i.e. minimum permissible power output for the commencing year) in the first twelve months after shipment

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 0.70%*nominal power lower than the minimum permissible power output for the previous calendar year for each twelve subsequent month period. So by the end of 25 years, at least 80.2% of nominal power can be achieved.

The Warranty Start Date is the day of sales or 12 months after modules dispatch from the Suntech factory, whichever occurs earlier.

If a module is found defective in material or workmanship, Suntech will, at its sole discretion, repair or replace the module by a functional module of the same type.

Suntech’s warranty terms do not apply to PV modules marked as “Grade A” or “Grade B” on the nameplate; for these kind of modules special warranties apply which have not been reviewed in the scope of this report. The warranty terms apply only to the end customer.

Warranty provisions, exclusions and limitations are generally in line with our expectations.

Should a dispute arise over a warranty claim, an independent testing body such as Fraunhofer ISE, TUV Rheinland or Verbands der Elektrotechnik (VDE) shall be involved to judge the claim finally. All fees and expenses associated with the test shall be borne by Suntech, we consider Suntech carrying these costs in the event of a warranty claim places it at the higher end of current market practice.

If the output power of the module is below the adjusted nominal power due to defects in material, Suntech will either repair or replace the module by a functional module of the same type. If Suntech no longer manufactures the respective module type, Suntech will either supply a functionally equivalent module of the same or higher power of a different type. Suntech will also compensate the proven lost profits of the defective module from the day of acknowledgement against Suntech.

OST considers Suntech’s provision to compensate for lost profit of the defective module to be above common marketplace practice. We also consider the positive nameplate capacity tolerance at the upper end of market standards, while the standard product warranty and the linear peak performance warranty are in line with current market standards.

We recommend an independent legal review of the warranty terms necessary to provide an opinion on suitability.

Product Liability Insurance

Suntech has provided two Product Liability Insurance policies, stipulated with Yingda Taihe Property Insurance and Chubb Insurance (China) Company Limited. OST has not reviewed the Yingda Taihe Property Insurance product liability insurance as it is not applicable to Europe or the UK.

OST has reviewed the Product Liability Insurance policy taken out with Chubb Insurance (China) Company Limited, effective from 10th March 2014 and valid until 10th March 2015. The general liability insurance policy covers bodily injury on persons and property damage arising out of the solar modules sold worldwide. Damages will be paid by insurance in case the Manufacturer is legally obliged to pay.

The insurance policy has an aggregate premium limit of USD 10,000,000, which is progressively reduced once a claim is paid, and a limit of USD 10,000,000 for each claim occurrence.

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Although the documentation on liability insurance was provided specifically for PV cells, modules and PV systems, which were all referred to as the ‘Product’, the wording of the document is not clear about the underperformance of the ‘Product. In particular, the policy excludes ‘Damage To Your Product’, where ‘Your Product’ is defined to mean goods or products manufactured by Suntech. ‘Your Product’ also includes representations or warranties made at any time with respect to the durability, fitness, performance, quality or use of ‘Your Product’. The policy defines terms of coverage and exclusions only in a general way and not specifically related with the Product’s application (e.g.: installation of modules on PV plants, roof-top or ground mounted, etc.).

We recommend that the terms of the Product Liability Insurance policies are reviewed by an insurance advisor to confirm that the arrangements are appropriate.

Environmental, Health and Safety Review

We have reviewed information provided by Suntech on their Environmental, Health and Safety (EHS) management system, and associated documentation, against relevant international lender Environmental, Health and Safety (EHS) guidelines, namely International Finance Corporation (IFC), World Bank, and the Equator Principles.

We have undertaken our review principally against the following relevant IFC Performance Standards categories:  Performance Standard 1: Assessment and Management of Environmental and Social Risks and Impacts  Performance Standard 2: Labour and Working Conditions  Performance Standard 3: Resource Efficiency and Pollution Prevention  Performance Standard 4: Community Health, Safety, and Security  Performance Standard 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources

Our findings and conclusions are based on a review of the environmental, health and safety information and data provided by Suntech.

Suntech has implemented a formal Environmental, Health & Safety (EHS) Management system. The environmental component of which is based on the ISO 14001 – Environmental Management System (EMS) standard. The Wuxi City manufacturing facility has been certified as compliant with ISO 14001 by SGS System Certification on 28/08/2013 (certificate valid until 5/08/2015). The health and safety elements have also been certified as compliant with ISO 18001 by SGS System Certification on 03/09/2013 (certificate valid until 01/09/2016).

The implementation of an ISO 14001 certified EMS demonstrates adequate management of environmental risks and meets the IFC Performance Standard 1. The implementation of ISO 18001 H&S Management System demonstrates adequate management of health and safety risks and meets the IFC Performance Standard 2.

We have received the latest test results for air emissions, wastewater discharges, and waste gas for the Wuxi facility, however these documents were provided in Chinese, therefore OST has been unable to fully review these in detail. OST has, however, been informed that all reports state that the factory meets all government requirements and therefore are in line the IFC Standards with regards to air emissions, wastewater discharges and waste gas levels. OST has

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also been informed that there have been no fines or notifications raised against Suntech’s Wuxi facility from the Government or Local Authority.

Suntech has provided a Certificate of Compliance from Wuxi Environmental Protection Authority however the document is in Chinese and cannot be fully reviewed, however we have been informed that it confirms that they comply with environmental laws and legislation. OST requests that a formal translation of this certificate into English is provided.

Overall we consider that Suntech meets the requirements set out in IFC Performance Standard 3 (Resource Efficiency and Pollution Prevention) with respect to supply chain. Although not required for primary supply chains, it should be noted that IFC Performance Standard 3 (Resource Efficiency and Pollution prevention), also includes requirements for the implementation of cost effective measures for improving efficiency in its consumption of resources and material inputs. OST has not received any specific information regarding what efficiency and resource measures have been put in place, or what quantifiable impacts this has had.

We consider that Suntech meets the requirements set out in IFC Performance Standard 4 (Community Health, Safety, and Security), as relevant for a primary supply chain.

However, Suntech has not provided information demonstrating their support and involvement in community based (CSR) projects through the provision of ‘sustained community development and employee initiatives.’ OST recommends that the Wuxi facilities investigate how they can further involve the local community with specific regard to the promotion and use of Solar PV, community development and education. We advise demonstrating this standard via the implementation of a formal CSR policy, which will measure quantifiable benefits to the local community.

We consider that Suntech meets the requirement set out in IFC Performance Standard 6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources) with respect to supply chain.

Following our review of information provided to OST Energy we consider that the Suntech production facilities are, in general, in-line with international lender requirements for a primary supply chain, based on IFC and World Bank standards.

We recommend that Suntech provides English versions of all relevant documentation in order for a full review to be carried out. We also recommend that information and company policy regarding continuing efficiency measures and pollution prevention is provided.

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1 Introduction

OST Energy has been appointed by Wuxi Suntech Power Co., Ltd (‘Suntech’ or ‘the Manufacturer’) to undertake an independent review of three models of Suntech poly-crystalline silicon photovoltaic (PV) modules. The purpose of the review will be to confirm the technical suitability of the modules for use in photovoltaic projects in the UK.

The following sections present a technical review of the three models of poly-crystalline modules rated 250Wp, 255Wp and 300Wp.

This review has been undertaken based on information provided via email, discussions with Suntech staff, independent testing, industry knowledge, a factory visit and information available in the public domain. While every effort has been made to verify source information, OST takes no responsibility for the completeness or otherwise of the information provided for the purpose of the review. We have only reviewed modules produced at the Wuxi facility located at 16 Xinhua Road, New District Wuxi, Jiangsu Province in China.

Our review has been undertaken in three phases as below and this report covers the scope of phases 1, 2 and 3:  Phase 1 – Desktop Review – Overview of the company – References – Technical review of PV modules – Module performance – Manufacturing faults – Acceptance in market place – Degradation warranty – Product guarantee – Environmental, Health & Safety (EHS) review  Phase 2 – Module testing – Maximum power measurement, Pmax – Visual inspection – Insulation test – Electroluminescence test – Additional tests  Phase 3 – Review of PV module production process – Factory quality – Manufacturing – Cell supply – Module testing equipment – Health and safety – Other

Our opinions on the PV modules are contained throughout the report and issues of most significance are discussed in the Executive Summary.

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2 Company Overview

2.1 Shunfeng Photovoltaic International

Suntech was acquired by Shunfeng Photovoltaic International (Shunfeng) at the beginning of 2014 following the insolvency of Suntech’s parent company Suntech Power Holdings Co., Ltd. Shunfeng, headquartered in Changzhou, Jiangsu province, China, focuses on the research, development, manufacturing and sales of silicon ingots, wafers solar cells and solar modules.

The acquisition of Suntech has resulted in a significant increase in Shunfeng’s PV cell production capacity from 650 MW to 2,250 MW per year and is seen as an indication of the company’s desire to increase its upstream capabilities in the solar supply chain.

Although not well established in Europe, Shunfeng is also a leading solar power plant operator in China, having developed 890 MWp of PV Plants in 2013. Shunfeng posted total revenues of USD 244 million in 2013 with a total number of 2,118 employees.

2.2 Wuxi Suntech Power Co., Ltd

As a subsidiary of Suntech Power Holdings Co., Ltd. Suntech was founded in 2001 as the main research and development and manufacturing subsidiary of the Suntech group. Based in Wuxi, Jiangsu province, China, at its peak in 2012 Suntech was the largest PV module manufacturer in the world with an annual production capacity of 2.5 GW and employed over 17,000 people worldwide.

The Manufacturer currently employs approximately 4,700 people worldwide involved in the production of mono-crystalline and poly-crystalline PV cells and modules, sale and distribution.

The principal activities of Suntech and its subsidiaries include:  Manufacturing of solar cells  Construction of PV systems  Manufacturing and trading of wafers  Research and development of solar cells and modules  Trading of PV systems  Power generation and plant operation  Trading machinery

Following the insolvency of Suntech Power Holdings Co., Ltd in early 2013 and the subsequent acquisition of Suntech by Shunfeng Group, the Manufacturer has undergone restructuring. The existing subsidiaries of Wuxi Suntech are illustrated in Figure 1 below.

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Figure 1: Wuxi Suntech subsidiaries

The existing principal businesses of Suntech include solar power generation and solar cell manufacturing. The current levels of R&D activities at the different subsidiaries have not been confirmed by Suntech.

2.2.1 Manufacturing capabilities

Suntech is based in Wuxi, Jiangsu, China, where the modules reviewed are manufactured. As a manufacturer of mono and poly-crystalline PV modules, Suntech is partially vertical integrated, because it does not process silicon ingots directly but produces modules from silicon wafer.

The Suntech PV module and cell manufacturing facilities consist of the following:

Table 2: Suntech manufacturing sites

Location Total Capacity for Wuxi Facility (City) Capacity (MW) Suntech (MW) Cell production Wuxi Suntech Power Co., Ltd. Wuxi 2,100 2,100 Co.,Ltd. Module production Wuxi Suntech Power Co., Ltd. Wuxi 2,300 2,300 (headquarter) Suntech Power Japan Saku-Shi 6 6 Corporation Nagano Plant Zhengjiang Fengyuan New Jiangsu 480 150 Energy Technoloy Co.,Ltd. SolarPark Korea Co., Ltd. Wanju-Gun 600 300 Wuxi Erquan Solar Energy Wuxi 240 120 Science & Technology Co., Ltd. Total capacity 3,626 2,876

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The Manufacturer’s other facilities in Japan and China are not reviewed in this report. We understand that some of the other facilities manufacture OEM modules. All the above facilities are included in the IEC certification provided by Suntech. .

2.3 Quality management system

Wuxi Suntech Power Co. Ltd holds the following international certifications issued by SGS S.A (PTY) Ltd:  ISO 9001:2008 - Quality Management Systems (expires on 16th August 2015)  ISO 14001:2004 - Environmental Management Systems (expires on 5th August 2015)  OHSAS 18001 - Health and Safety Management Systems (expires on 1st September 2016)  SA 8000:2008 - Social Accountability International (SAI) (expires on 10th September 2016)

Suntech also holds a Japan Electrical Safety & Environment Technologies Laboratory (JET) PVm certification of conformity to performance and safety tests, based on the relevant international standards (IEC61215 & IEC61730) (expires on 6th December 2017 for the STP XXX-24/Ve modules and on the 7th July 2016 for the STP XXX-20/Wd).

The above are internationally recognised certifications, which we would expect a major PV module manufacturer to hold. The objectives of the Quality Management System are:  To maintain an effective Quality Assurance System which complies with BS EN ISO 9001: 2008  To ensure compliance with individual contract specifications and relevant statutory and safety requirements  To minimise losses during manufacture of materials and finished product  To achieve a level of quality of products and services which enhances the company’s reputation with its customers and where possible to maximise customer satisfaction

Suntech has provided OST with its Quality Control Plan (file name: ‘PV Module Control Plan’). The document describes the Quality Management approach (specification, inspection method, frequency of inspection, standard) for processes from delivery of material and components to the packing of the finished modules.

In addition, Suntech has provided an incoming quality control (file name: ‘IQC Suntech’) program and a process inspection control program (additional details are outlined in Section 6). Non- conforming components and materials are manually segregated and repaired. Repaired items are again subjected to appropriate inspection. We note that records of incoming inspections are maintained for two inspection visits. Furthermore, a supplier audit is conducted to evaluate the supplier’s ability of production process and quality control as well as EHS and Corporate Social Responsibility. Existing local suppliers are audited once a year and qualified strategic suppliers are audited quarterly.

According to Suntech’s quality documentation, suppliers of components are evaluated according to the procedure described in the document “STP-P-10 Control Procedure of Strategic Material Procurement Process”. This document provides standard checks for suppliers’ products to guarantee the product quality of purchased materials.

Moreover, Suntech has provided the following documents:  OQC work instruction  Supplier assessment report

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 Supplier audit  Management policy  Control procedure of strategic material procurement process  Test equipment list  A factory inspection report by VDE  Training plan and procedure

A competence, training and awareness program control is also present but OST has only been provided with a document in Chinese. The purpose of the competence, training and awareness program control is to establish an effective control of the training budget management and training system planning, monitoring and evaluation of the effectiveness of training and other related activities to ensure the effectiveness of the training and to regulate the internal training guide. Only a brief overview of the training procedure has been provided by Suntech for review and has been included in Section 6.5. The provided training plan includes the following:  Training requirements (for each position)  Training plan (yearly training and monthly training)  Several types of trainings (New employee and new assignment, on job training, improvement training and special job training)  Evaluation criteria (only trainees with passing grades are allowed to move to next level training)

Based on the quality documentation and sighted SGS certifications in place, we consider Suntech’s quality management system to be in line with our expectations and industry standards.

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3 Technical Review of Suntech PV Modules

This section outlines the technical characteristics and the certifications of the Suntech PV modules reviewed in this report; the polycrystalline STP250-20/Wd, STP255-20/Wd and STP300- 24/Ve models.

3.1 Module technical characteristics

The following table shows the technical characteristics of the modules at Standard Test Conditions (STC) of 1000W/m2, module temperature 25°C, Air Mass (AM) 1.5 as outlined on the manufacturer’s module datasheets provided for review.

Table 3: Technical characteristics of Suntech modules reviewed (at STC) Unit STP250- STP255- STP300- Parameter 20/Wd 20/Wd 24/Ve Nominal power Wp 250 255 300 Tolerance % 0 / +5 Voltage at Pmax - (Vmpp) V 30.7 30.8 35.9 Current at Pmax - (Impp) A 8.15 8.28 8.36 Open Circuit Voltage (Voc) V 37.4 37.6 44.5 Short circuit current (Isc) A 8.63 8.76 8.83 Module efficiency % 15.4 15.7 15.5 Maximum System Voltage (IEC) V 1000 DC By-pass diodes 3 Temperature coefficient of Pmax % / °C -0.43 Temperature coefficient of Voc % / °C -0.33 Temperature coefficient of Isc % / °C +0.067 Max series fuse rating A 20 Normal Operating Cell °C 45±2 Temperature (NOCT)

The characteristics of the Suntech modules above are in line with our expectations and industry standards for crystalline modules.

The actual power of the modules should be confirmed by the flash tests of all the modules provided by the manufacturer on delivery.

The positive power tolerance of the modules results in effective tolerance values of 12.5W, 12.75W and 15W for the three modules which we think is above market standards.

3.2 Low irradiance performance

The performance of a PV module varies as soon as the module is exposed to a reduced irradiance from the STC irradiance of 1,000 W/m2. The Manufacturer has provided low irradiance tests which were performed externally by National Center of Supervision & Inspection on Solar

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Photovoltaic Products Quality (CPVT). The low irradiance tests were performed on samples of STP255-20/Wd and STP300-24/Ve at irradiance levels of 1,000, 800 and 200 W/m2. OST would also expect the Manufacturer to provide low irradiance tests performed at 400 and 600 W/m2 to allow an analysis of the performance at intermediate levels of irradiance. We note that both modules were also tested at NOCT of 800 W/m2 and temperature of 43.30C for STP255-20/Wd and 44.70C for the STP300-24/Ve.

The NOCT performance data was corrected to 250C with a correction factor provided by CPVT. Low irradiance test results from the independent tests carried out by IPSol on the STP255-20/Wd modules as well as the independent measurement results on the STP250-20/Wd and STP300- 24/Ve provided by Suntech are included in the following figure.

Figure 2: Low irradiance performance for the modules reviewed

104%

102%

100%

98%

96%

Performance (%) Performance 94%

92%

90% 100 200 300 400 500 600 700 800 900 1000 W/m2 STP250-20/Wd STP300-24/Ve STP255-20/Wd (IPSOL) Typical Shape

Considering the figure above, the results from the tests show that the low irradiance performance and curved shape are in line with our expectations, excluding the 94.4% performance at 200 W/m2 for the STP300-24/Ve module. We would expect the performance at 200 W/m2 to be at least 95% of the performance at 1,000W/m2. We would typically expect to see a curvilinear shape, with a slight increase in efficiency at lower than 1,000 W/m2 up to 400 W/m2 and a more accentuated drop at irradiances lower than 400 W/m2 for crystalline technology modules (as the red expected curve in the Figure above).

Although STP300-24/Ve module exhibits a drop in relative efficiency at 200W/m2 of more than 5%, in general, the low irradiance performance of the STP300-24/Ve, STP250-20/Wd and STP255-20/Wd modules are in line with our expectations.

3.3 Module efficiency

The cell efficiency is the ratio of the total energy of the absorbed light versus the electrical energy output. Depending on the photovoltaic material used panels produce electricity from a range of

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frequencies of light, but cannot cover the entire solar spectrum. Typical commercial pc-Si cells have an efficiency that ranges between 16 and 20% which is considered industry standard. The efficiency of photovoltaic materials is limited by losses associated with thermodynamic, electrical and quantum principles, hence much of the incident sunlight energy that reaches a photovoltaic cell is not converted into DC electricity.

The module efficiency measures this conversion rate over the whole module area, taking into account inactive surfaces such as gaps between cells and the contacts. Typical commercially available pc-Si modules consist of 48, 60 or 72 125 mm x 125 mm, or 156 mm x 156 mm photovoltaic cells connected in series. Module manufacturers are able to provide a variety of module power classes by sorting their cells by efficiency; for example a manufacturer’s highest efficiency cells are grouped together to produce its highest rated power module.

The range of efficiency of the Suntech modules reviewed is in line with our expectations and the industry standard.

3.3.1 Manufacturer comparison

The following section compares the module efficiency of the Suntech modules reviewed to a range of other polycrystalline modules with the same nominal power sold in the PV market and produced by top-tier and reputable manufacturers.

Names of other modules and manufacturers used in the comparison have been omitted. Modules have been referred to using the initial “Mx”, where the “x” is a casual number correspondent to a manufacturer.

The STC and NOCT efficiencies are derived directly from the datasheets provided by Suntech and other manufacturers and available in the public domain.

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3.3.1.1 STP250-20/Wd – 250Wp Table 4: Efficiency comparison (Suntech STP250-20/Wd) Manufacturer Power (STC) [ W ] Efficiency (STC) [%] Efficiency (NOCT) [%] M1 250 15.22% 14.27% M2 250 15.54% 14.07% M3 250 15.30% 13.96% M4 250 14.97% 13.92% M5 250 15.32% 13.86% M6 250 14.91% 13.78% M7 250 15.27% 13.82% Suntech 250 15.40% 14.21%

Figure 3: STP250-20/Wd efficiency comparison at STC Figure 4: STP250-20/Wd efficiency comparison at NOCT

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3.3.1.2 STP255-20/Wd – 255Wp Table 5: Efficiency comparison (Suntech STP255-20/Wd) Manufacturer Power (STC) [ W ] Efficiency (STC) [%] Efficiency (NOCT) [%] M1 255 15.58% 14.05% M2 255 15.45% 14.62% M3 255 15.71% 14.47% M4 255 15.78% 14.38% M5 255 15.59% 14.03% M6 255 15.67% 14.52% M7 255 15.61% 14.23% Suntech 255 15.70% 14,45%

Figure 5: STP255-20/Wd efficiency comparison at STC Figure 6: STP255-20/Wd efficiency comparison at NOCT

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3.3.1.3 STP300-24/Ve – 300Wp Table 6: Efficiency comparison (Suntech STP300-24/Ve) Manufacturer Power (STC) [ W ] Efficiency (STC) [%] Efficiency (NOCT) [%] M1 300 15.63% 14.20% M2 300 15.41% 14.00% M3 300 13.56% 12.49% M4 300 15.15% 13.76% M5 300 15.25% 13.54% M6 300 15.46% 14.11% M7 300 13.34% 12.08% Suntech 300 15.50% 14.11%

Figure 7: STP300-24/Ve efficiency comparison at STC Figure 8: STP300-24/Ve efficiency comparison at NOCT

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3.3.2 OST comments

The comparisons above have been made considering producers on the global market supplying comparable products (same technology and same nominal output). From the figures above we consider that the Suntech 250Wp and 300Wp modules reviewed show STC and NOCT efficiencies above average by market standards. The 255Wp modules showed average STC efficiency but a NOCT efficiency slightly above average. We consider this to be indicative that the cells used by Suntech are of suitable quality for the 250Wp, 255Wp and 300Wp modules.

3.4 Fill Factor

An additional parameter for the evaluation of the performance of a solar PV module is the Fill Factor, which is defined as the ratio between the actual maximum obtainable power and the theoretical power (VOC X ISC). Graphically, the Fill Factor is a measure of the "squareness" of the solar cell IV curve and can be also expressed as the ratio of the area of the largest rectangle which fits under the IV curve to the area of the rectangle defined by the theoretical power (Figure 9). Standard commercial available solar cells have a Fill Factor greater than 70%. A higher Fill Factor indicates that less current produced by the light is dissipated in internal losses due to the series and parallel resistances within the cells themselves. We have analysed the Fill Factor at STC and NOCT.

Figure 9: Graphical representation of Fill Factor

3.4.1 Manufacturer comparison

The following section compares the Fill Factor of Suntech’s modules and other modules currently available on the market with the same technology (polycrystalline) and same nominal power output produced by top-tier and reputable manufacturers.

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3.4.1.1 STP250-20/Wd – 250Wp Table 7: Fill Factor comparison (Suntech STP250-20/Wd) Manufacturer Power (STC) [ W ] Fill Factor (STC) Fill Factor (NOCT) M1 250 75.85% 73.81% M2 250 75.71% 73.81% M3 250 79.26% 72.95% M4 250 77.34% 76.31% M5 250 77.64% 75.75% M6 250 76.15% 75.41% M7 250 75.30% 72.75% Suntech 250 77.52% 76.30%

Figure 10: STP250-20/Wd Fill Factor comparison at STC Figure 11: STP250-20/Wd Fill Factor comparison at NOCT

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3.4.1.2 TP255-20/Wd – 255Wp Table 8: Fill Factor comparison (Suntech STP255-20/Wd) Manufacturer Power (STC) [ W ] Fill Factor (STC) Fill Factor (NOCT) M1 255 75.82% 73.23% M2 255 76.31% 75.81% M3 255 76.56% 75.95% M4 255 75.58% 73.22% M5 255 75.10% 74.53% M6 255 76.77% 74.77% M7 255 74.98% 73.44% Suntech 255 77.43% 75.98%

Figure 12: STP255-20/Wd Fill Factor comparison at STC Figure 13: STP255-20/Wd Fill Factor comparison at NOCT

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3.4.1.3 STP300-24/Ve – 300Wp Table 9: Fill Factor comparison (Suntech STP300-24/Ve) Manufacturer Power (STC) [ W ] Fill Factor (STC) Fill Factor (NOCT) M1 300 75.74% 73.77% M2 300 76.79% 74.47% M3 300 74.39% 74.48% M4 300 79.02% 77.40% M5 300 75.12% 73.67% M6 300 75.55% 75.28% M7 300 73.84% 71.72% Suntech 300 76.38% 75.44%

Figure 14: STP300-24/Ve Fill Factor comparison at STC Figure 15: STP300-24/Ve Fill Factor comparison at NOCT

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3.4.2 OST Comments

From the above figures we note that all modules have fill factors above the industry standards for polycrystalline modules at both STC and NOCT. The STP255-20/Wd had the best Fill Factor of all modules compared in this review. This indicates that the cells utilised by Suntech are of satisfactory quality.

3.5 Conclusions on manufacturers comparison

The following tables summarize the efficiency and Fill Factors of Suntech modules and the averages of nine different manufacturers, including Suntech.

Table 10: Efficiency and Fill Factors summary table Efficiency Fill Factor (STC) Fill Factor(NOCT) Module Efficiency (STC) (NOCT) STP250-20/Wd 15.40% 14.21% 77.52% 76.30% STP255-20/Wd 15.70% 14.45% 77.43% 75.98% STP300-24/Ve 15.50% 14.11% 76.38% 75.44%

Table 11: Average Efficiency and Fill Factors summary nine manufacturers Efficiency Fill Factor (STC) Fill Factor(NOCT) Module Efficiency (STC) (NOCT) 250 - Wp 15.26% 13.98% 76.80% 74.38% 255 - Wp 15.67% 14.31% 76.00% 74.50% 300 - Wp 14.98% 13.54% 76.00% 74.70%

We note that Suntech STP250-20/Wd and STP300-24/Ve modules reviewed show STC efficiencies slightly above average. However, the STP255-20/Wd module has average STC module efficiency. However all modules displayed NOCT efficiencies above average by standards of the considered market.

All Suntech modules have fill factors above industry standards for polycrystalline modules at both STC and NOCT and the fill factors of the STP2555-20/Wd module ranked high above average market offering.

3.6 Certifications

The Suntech modules reviewed in this report, which are going to be used in the UK, hold the following certifications which are summarized in the table below.

Table 12: Summary of certifications Certification Description Required Certified IEC61215 Crystalline silicon terrestrial PV modules, design √ √ qualification, and type approval. IEC61730 PV module safety qualification, Parts 1 and 2; requirements for construction and testing, √ √ including protection class II.

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Certification Description Required Certified IEC61701ed. 2, Salt mist corrosion test; requirements of PV x √ severity 1. modules in salt-laden air. IEC 62716 ed. 1.0. Certificate for ammonia corrosion test. x √ MCS BBA 0007 Is to achieve a micro-generation quality assurance scheme that is in accordance with x √ documented standards, a requirement for Government incentives in the UK. CSA - UL1703 Is to achieve compliance with regulation in the USA and Canada provide increased assurance x √ of quality and safety. ISO9001:2008 Certification for quality management system x √ ISO14001:2004 Certification for environmental management x √ system. OHSAS18001:2007 Certification for occupational health and safety x √ management system. JET PVm JET (Japan Electrical Safety & Environment Technology Laboratories) is to comply to various performance and safety tests (conformity tests) x √ based on the relevant international standards (IEC61215 & IEC1730) and have been manufactured under the strict quality control. CE Marking It is to achieve compliance with EU Product √ √ Safety Regulations and Low Voltage Directive. SGS certificate for desert dust test (issued on 12th September 2012). x √ Certificate for PV cycle for the disposal of PV modules after x √ dismantling

We consider the above certifications to be in line with market standards and appropriate for use in the EU and UK.

3.7 Returns

OST has been provided with a summary of customer complaints about module quality made to the factory, for the year 2013, after Suntech Power Holdings declared insolvency in early 2012. The Manufacturer has provided a summary of all module complaints for the year 2013, with details about the defect detected.

Table 13: List of complaints Date Defect description QTY (no of modules) 2013 Broken cell 3 Broken glass 1 Broken junction box 2 Bubble on backsheet 2

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Date Defect description QTY (no of modules) Damaged/Wrong frame 12 Dent on backsheet 1 Low/No output 16 Silicone residue on module 3 Stain on glass 6 Wrong insulation stipe in lamination 1 Wrong nameplate or datasheet 5 White spot around ribbon 2 Stain on module 2 2013 Total 56

Figure 16: Claims by type - 2013

The above pie chart categorises the defects by type. During the year 2013, the Manufacturer received 17ppm module complaints, of which 6ppm were claims made after installation. It appears that the majority of the defects arose during production. While the incidence of replacements is negligible; OST cannot comment on the increase or decrease of complaints, relative to previous years. The Manufacturer should provide documentation about the number of warranty claims and returns for products for at least a number of years.

OST notes that the Manufacturer provided a customer claim list, declaring that all claims have been closed, however, it is not clear whether these claims were accepted or invalid. The

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Manufacturer has not provided further details about claims in order to evaluate the complexity level of the claim procedure.

We note that the analysis of returns undertaken in this section applies to Suntech Power Holdings modules previously manufactured at the facility with similar set of components and machinery. We also note that Suntech issued in a Customer Warranty Letter on its home page on the 18th April 2014, stating that the Manufacturer will continue to underwrite all the product and performance warranties for the products manufactured in the past and contracts entered no matter before or after the start of its restructuring phase on 20th March 2013. Thus, due to the continuity of warranties on products manufactured in the past and the similarity with the Suntech modules currently manufactured, we consider that the analysis above can be taken as representative.

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4 Module Testing

As part of our review, a set of validation tests were carried out on a set of 11 modules (model STP255-20/Wd (255Wp)), selected by OST Energy, at IPSol Energy laboratories in Nottingham. The tests and measurements made by IPSol were intended to probe the reliability and manufacturing quality of the modules and also to assess their performance.

4.1 The set of validation tests

The devices under test (DUTs) were Suntech STP255-20/Wd polycrystalline solar PV modules. The sample of 11 modules tested was selected by OST Energy. The set of validation tests was carried out during May/June 2014 and the following tests were undertaken to assess the modules’ quality and reliability:  Visual inspection  Maximum power measurement  Electroluminescence testing  Insulation testing  Performance at NOCT  Performance at low and intermediate irradiances  Thermal imaging/∆T  Hot-spot endurance test  Potential induced degradation test

The set of modules tested was selected by OST and provided by the Manufacturer. The serial numbers of the modules tested are given below. The tests undertaken on each module are outlined in the table. One of the modules was utilised as a control for the PID test.

Table 14: Module serial numbers Module number Module serial number Type of test 1 0B2314262020501814 Visual inspection 2 0B2314262020411814 Maximum power determination 3 0B2314262020371814 Insulation test 4 0B2314262020471814 Performance at NOCT Performance at low irradiance 5 0B2314262020181814 Performance at intermediate irradiance 6 0B2314262020421814 PID control module 7 0B2314262020261814 Hot-spot endurance test 8 0B2314262020251814 Thermal Imaging & ΔT 9 0B2314262020161814 Electro-luminescence 10 0B2314262020041814 Potential Induced Degradation 11 0B2314262020091814

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4.1.1 Visual inspection

Five of the modules were inspected on arrival and assessed against IEC EN 61215:2005 visual inspection criteria. For a module to pass these criteria it must be free of major visual defects. According to Section 10.1 of IEC 61215:2005, the modules are inspected under illumination of not less than 1,000 lux for the following conditions:  Cracked, bent, misaligned or torn external surfaces;  Broken cells;  Cracked cells;  Faulty interconnections or joints;  Cells touching one another or the frame;  Failure of adhesive bonds;  Bubbles or delamination forming a continuous path between a cell and the edge of  the module;  Tacky surfaces of plastic materials;  Faulty terminations, exposed live electrical parts;  Any other conditions which may affect performance;  Failure of adhesive bonds;  Visual bond check of junction box sealing;  Visual bond check of frame & mounting sealing.

Scratches to cell surfaces were present on all modules examined. However, such defects were minor in nature and all modules were deemed to have passed the visual inspection.

4.1.2 Maximum Power measurement

Maximum power measurements were taken to assess the performance of the modules at STC (25°C, 1000W/m2, 1.5 AM) and to compare with the manufacturer’s declared rated output. The modules tested were labelled as having a power output at STC of 255W with tolerance of -0/ +5%. The results of the tests are included in the following table.

Table 15: Maximum Power measurement results Serial number of module Power at STC [W] Difference to nameplate 0B2314262020261814 259.3 1.69 % 0B2314262020251814 258.6 1.41 % 0B2314262020161814 256.1 0.43 % 0B2314262020041814 257.8 1.10 % 0B2314262020091814 258.8 1.49 % Average 258.1 1.22 %

The range of outputs recorded for the modules tested was 258.8W to 259.3W1. The narrow range of values for Isc, Imp, Voc and Vmp across the sample suggests a consistent quality.

We note that the average Fill Factor of 76.0% is in the range expected for 255W polycrystalline modules.

1 The uncertainty of measurement for Pmpp is max ±2.5%, Isc is max ±2.3%, Voc is max ±1.0%.

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4.1.3 Electroluminescence imaging

IEC 61215 does not require electroluminescence (EL) imaging to be undertaken on the modules as part of the test procedures; however, the modules were imaged using an electro-luminescence (EL) technique which shows defects not detectable in a visual inspection such as micro-cracks, short circuits, finger interruptions and other manufacturing defects. The images were assessed using the IPSol Energy Classification System and graded A to C (with A being of highest quality and C of lowest).

All modules tested were adjudged to be of class A with the images indicating no significant micro- cracking or other production defects. The cells appeared to be of a consistently high quality and well matched within each module imaged.

4.1.4 Insulation test

The five modules were subjected to an insulation test according to IEC EN 61215:2005 10.3. Insulation resistance is an electrical safety test. The purpose is to determine whether a module has a sufficient electrical insulation between its current carrying parts and the frame (or the outside world). A dielectric strength tester is used to apply a DC voltage source of up to 1000V plus twice the maximum system voltage (3000V).

All modules passed the test and demonstrated insulation resistances greatly in excess of the pass criterion.

4.1.5 Performance at NOCT

The maximum power at STC is universally quoted when evaluating PV modules. This is primarily because these specific conditions are relatively easy to reproduce in the laboratory. STC conditions are however rarely seen in the real world so by measuring power output at other conditions a data set can be generated that can be used to validate a manufacturer’s performance curves and serve as a guide to how a module may perform in the field.

Nominal Cell Operating Temperature (NOCT) is defined as the equilibrium mean solar cell junction temperature within an open rack mounting system at 800Wm2, 25°C and wind speed of 1ms and is determined by testing according to IEC EN 61215. The NOCT value declared by the manufacturer for the modules tested was 45±2oC.

Table 16: results of measurement at NOCT Serial number of module Power at NOCT [W] 0B2314262020411814 187.8 0B2314262020371814 189.4 0B2314262020471814 188.7 0B2314262020181814 188.7 0B2314262020411814 188.3

The minimum measured power output at NOCT was 188.3W. The average of five tested modules was 188.6, 1.95% above the manufacturer’s declared value of 185.0W.

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4.1.6 Performance at low and intermediate irradiance

Measurements of power output at irradiances of 200, 400, 600 and 800 W/m2 were taken on five modules. As with the measurements at STC, the results at each irradiance level were confined to a very narrow range implying a consistent quality. The average values were the following:

Table 17: Low and intermediate irradiance performance P at P at P at P at P at Serial number of 200W/m2 400W/m2 600W/m2 800W/m2 1,000W/m2 module (W) (W) (W) (W) (W) 0B2314262020501814 50.0 102.6 155.2 206.6 258.1 0B2314262020411814 50.3 103.1 155.8 207.7 259.6 0B2314262020371814 50.1 102.8 155.2 206.8 258.2 0B2314262020471814 50.2 102.9 155.5 207.2 258.6 0B2314262020181814 50.1 102.7 155.1 206.6 258.0 Average 50.1 102.8 155.4 207.0 258.4

Figure 17 below shows the relative efficiencies for different irradiation levels of all of the five modules tested by IPSol.

Figure 17: Relative low irradiation efficiencies of the modules tested by IPSol Relative efficiency 100.50% 100.00% 99.50% 99.00% 98.50% 98.00%

97.50% Relative efficiency (%) efficiency Relative 97.00% 96.50% 200 300 400 500 600 700 800 900 1000 Irradiance (W/m2)

0B2314262020501814 0B2314262020411814 0B2314262020371814 0B2314262020471814 0B2314262020181814 Average

In general, the relative efficiency of the five modules at low irradiance tested by IPSol is in line with our expectations.

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4.1.7 Thermal imaging & ΔT

Thermal imaging is used to assess mismatch of cell classes used in an individual module that could give rise to hot-spot overheating. ∆T is the difference between the temperature of the hottest cell and the mean temperature of the module after being exposed to simulated sunlight under short circuit conditions. A high value of ∆T could be evidence of poorly matched cells but also could be evidence of damage to individual cells. All modules tested recorded a ∆T of less than 10°C with four modules of the sample recording values of less than 7.5°C.

These values suggest the cells in the modules tested are electrically well matched.

4.1.8 Hot spot endurance test

The purpose of this test is to determine the ability of a module to withstand hot-spot heating effects, for example solder melting or deterioration of the encapsulation. These defects can be provoked by cracked or mismatched cells, interconnect failures, partial shadowing or soiling. To satisfy the criteria detailed in IEC EN 61215 the most ‘vulnerable’ cell in a module is stressed for a period of five hours.

To establish if any deterioration to the module results from hot-spot stressing it is necessary to repeat the power measurement, insulation resistance and wet leakage tests before and after hot- spot stressing. To satisfactorily pass the test the module must show no ‘major visual defect’, power output must not decrease by more than 5%, and insulation resistance and wet leakage must meet the criteria set down in IEC EN 61215:2005.

There was no evidence of visual degradation in any of the modules after hot-spot stressing with the change in power after stressing being statistically insignificant. The modules also passed insulation resistance and wet leakage testing after stressing, and were thus deemed to have passed the test.

4.1.9 Potential Induced Degradation test

Power loss of a PV module can occur due to stressing of the junction of the cell because of the system voltage between the frame and the laminate. By knowing the vulnerability of a module to PID, preventive measures can be taken to minimise this source of power loss in an installation (e.g. inverter selection, grounding design). The PID test simulates conditions where potential induced degradation can occur by applying the manufacturer’s declared maximum system voltage between the laminate and the module frame in damp heat conditions.

The modules under test are stressed at 1000V for a period of 96 hours at 60°C and 85%RH according to the draft standard IEC 62804. Electroluminescence images are taken before and after stressing to assess degradation. Change in power output (∆P) is also measured. Modules with a ∆P <5% are adjudged class A; 5%<∆P<30% class B; and ∆P >30% class C. A control module is included in the test to make certain any degradation observed is the result of PID stressing and is not solely a result of the damp heat conditions. In the modules under test an average of 2.1% degradation was observed meaning they were given an ‘A’ classification for PID resistance.

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4.1.10 Conclusions

All modules tested were generally of a high quality, with power outputs across a range of conditions meeting or exceeding the manufacturer’s quoted values. There was a narrow spread in the results for the five modules that underwent performance testing suggesting a consistent quality of module across the sample. Resistance to hotspot stressing was excellent, with the values for ΔT suggesting the cells in the modules tested were appropriately matched. A small drop in power output was evident in PID stressing but the results remained comfortably inside the ‘A’ classification for PID resistance.

The EL and thermal imaging showed the cells of the modules tested to be well matched and of a high quality, as would be expected for a module of a rated output of 255W.

While the test results are promising we do not consider it possible to draw any profound conclusions regarding the population(s) from which the samples were taken.

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5 Review of Production Machines and Key Components

5.1 Suppliers of production machines

Module production is undertaken at the Suntech facilities with machines from a number of suppliers. The manufacturing equipment suppliers for production processes are listed in the tables below.

Table 18: Suppliers of production equipment Capacity per Origin of machine per Name Type QTY Supplier shift (pcs) Supplier Note Cutting DM11 1 Changzhou, 4351 Changzhou Demao Automation Changzhou Demao Automation machine China Technology Co., Ltd Technology Co., Ltd. produces EVA/TPT photovoltaic equipment. The production includes solar cell module equipment, automatic cutting machine, automatic group box machine, dryer and corner solar module production line. No details have been found in the public domain and neither in the documentation provided by Suntech, so OST cannot comment on the reliability of this supplier. BX-STE2 9 n/a 4351 Shanghai Boxianshiye Co., Ltd No information has been found in the public domain so OST cannot comment reliability of this supplier Tabbing TOYAMA DF2 1 Japan 160 Stream Co., Ltd Toyama Kikai K.K. was founded in

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Capacity per Origin of machine per Name Type QTY Supplier shift (pcs) Supplier Note Machine TOYAMA DF3 1 160 1963. Company headquarters are located in Osaka, Japan. Most sales of tabbing machines are to Chinese companies however Toyama has sold a considerable amount to the Japanese, Korean and European markets. Limited information has been sighted regarding Toyama, however based on physical inspection, the equipment appears to be of satisfactory standard to not cause any material concern. XCell3300 1 USA 180 Komax Systems York Komax Solar is an established supplier of manufacturing machinery to the photovoltaic industry. Komax Group is headquartered in Switzerland and has facilities in France, USA and Malaysia. It is a manufacturer for wire processing, solar and medical technology. Komax Group was founded in 1975 and currently has approximately 1000 employees. An acquisition of the tabbing machine company Ascor started their solar section and the dedicated solar wing Komax Solar was created in 2009. In the solar

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Capacity per Origin of machine per Name Type QTY Supplier shift (pcs) Supplier Note field, Komax is a worldwide supplier of machines for the production of crystalline and thin-film modules. The machines include stringers, lay- up systems, and laminators, which take care of the final stage of sealing the fragile matrices. The release of their new Stringer X2 machine in the first half of 2010 increased Komax Solar sales to 17.7 Million GBP. OST are confident in Komax’s ability to use their extensive experience to produce high quality production machines. SL200 2 Spain 189 Electricidad Gorosabel Electricidad Gorosabel was established in 1957 and focussed on supporting the industrial automation sector until 1999 when a new division was created within the company, Gorosabel Solar Energy. The company manufactures machines for tabbing/stringing, sun simulators, framing and cell testing/sorting. Gorosabel is based in northern

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Capacity per Origin of machine per Name Type QTY Supplier shift (pcs) Supplier Note Spain but has distributors in China/India as well as Endeas in Spain. The company provides references to customers such as Suntech, Canadian Solar, AUO, Yingli and others although it has not been stated what equipment has been supplied to these module manufacturers. The Group as a whole has 80 professional employees and 3500m2 of manufacturing facilities, although the extent of this that is allocated to the solar division has not been confirmed. The division Gorosabel Automatica is ISO 9001 accredited but it has not been confirmed whether this also applies to the solar division. We consider Gorosabel to be an established supplier for Stringer/Layup machines. Mandragon 2 Spain 189 Mondragon Assembly S.Coop Mondragon Assembly is an international group that specializes in the development of integrated automation solutions. Founded in

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Capacity per Origin of machine per Name Type QTY Supplier shift (pcs) Supplier Note 1954, the group now has more than 280 companies and employs 80,000 people. With sound experience in automation, Mondragon Assembly delivers a comprehensive range of high-speed automated machines and solutions. We are comfortable that Mondragon Assembly has suitable experience in the production of tabbing machines. TT1200HS 5 Germany 236 Teamtechnik Maschinen Teamtechnik is a German company with 30 years of experience in development and construction of automotive equipment. It is a leader in the market with its high- performance systems and non- contact soldering process. We consider the company to be an established supplier. LDTS1400B 37 Germany 222 Wuxi Lead Auto Equipment Co., Wuxi Lead Auto is a new energy und Anla Ltd automation equipment manufacturer, integrating equipment R&D, parts purchasing, processing, assembly, programming, debugging, and after-sale service. No further details have been found in the

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Capacity per Origin of machine per Name Type QTY Supplier shift (pcs) Supplier Note public domain and neither in the documentation provided by Suntech, so OST cannot comment on the reliability of this supplier. Conveyance Cascade 18 Suzhou, China N/A Kuttler Automation Systems Co., Kuttler Automation is manufacturer line machine SCA1300 Ltd of automation systems for the Test SC1100 13 N/A printed circuit board industry. Located in Germany and China, the Framing Kuttler (Amfl- 6 661 manufacturer employs 100 Machine D0146) employees world-wide. The El Testing Kuttler 11 728 manufacturer has a 25 year experience in automation solutions. The manufacturer has expanded its business in Europe and worldwide. We consider the company to be an established supplier. Laminator ICOLAM 44/23 32 Germany 174 Meier Solar Solutions Gmbh Meier Solar Solutions Gmbh, ICOLAM 28/18 2 formerly Meier Vakuumtechnik GmbH is a manufacturer of PV 15 layers 1 433 laminators. NPC Europe GmbH, the leading Japanese manufacturer of machines and systems for the photovoltaic industry and Meier Solar Solutions GmbH have merged to form a new company named NPC-Meier GmbH. No details have been found in the public domain and

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Capacity per Origin of machine per Name Type QTY Supplier shift (pcs) Supplier Note neither in the documentation provided by Suntech, so OST cannot comment on the reliability of this supplier. LM-S-14×240 1 Japan 37 NPC NPC Incorporated was founded in LM-SA- 1 109 1992 for the purpose of production 170X260-S and sale of vacuum packing machines. In 1994, NPC developed LM-SA- 1 109 the Module Laminator entering into 215X320-S the photovoltaic market. Since then, NPC released a series of new machines including Cell Testers, Tabbing and Stringing Machines, Module Testers and other peripherals to the market, providing a complete line-up for manufacturing photovoltaic modules. The company has expanded its business worldwide, including Europe (Germany), China, Taiwan, Korea and the US. Products offered include fully automated Crystalline Silicon and Thin film Module Assembly Lines and a variety of single unit devices. We consider NPC to be a reputable

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Capacity per Origin of machine per Name Type QTY Supplier shift (pcs) Supplier Note manufacturer of machinery for PV module production. CYY- 12 133 Shanghai Difa Automation Shanghai Difa Automation A3400DGM Equipment Co., Ltd Equipment Co., Ltd is a manufacturer of solar module laminating machines. The company holds the following certification: management certification: ISO 9000/9001/9004/19011: 2000. No further information has been found in the public domain so OST cannot comment reliability of this supplier. 2200*4400(23/ 42 Wuxi, China 177 Wuxi Shang'en Technology Co., No information has been found in 36) Ltd the public domain so OST cannot Automatic 10000*1200*20 11 N/A comment reliability of this supplier. conveyance 00 line machine Framing Manual 41 Wuxi, China 730 Wuxi Xingjiang Jiayuan No information has been found in Machine hydraulic Technology Co., Ltd the public domain so OST cannot pressure comment reliability of this supplier. Semi-automatic 6 661 air pressure Final Testing PSS8 33 Germany 691 BERGER Lichttechnik GmbH & BERGER Lichttechnik was Co.KG established in 1960 with the development and production of

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Capacity per Origin of machine per Name Type QTY Supplier shift (pcs) Supplier Note photographic testers. The company sold the first flasher to the German space company MBB in 1973 and following this, BERGER has developed a wide range of products for terrestrial and extra-terrestrial solar simulation and testing of solar modules, arrays and cells. The website details a number of PV industry references including Q.Cells, REC Solar, Suntech and TUV Rheinland Group. We are comfortable that BERGER has suitable experience in the production of flash testers. El Testing EL-A 2 Shanghai, 728 ASIC Shanghai Co.,Ltd ASIC have been providing solar EL China testing machines since 2009. They are based in Shanghai and supply many of the surrounding Chinese PV module manufacturers such as JA Solar, Trina Solar, Yingli Solar and Jinko Solar. Despite having only five years manufacturing history and limited information in the public domain, the extensive top-tier customer list

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Capacity per Origin of machine per Name Type QTY Supplier shift (pcs) Supplier Note suggests acceptability. OPT-M140DA 8 Shanghai, 728 Shanghai Optech Science And Shanghai Optech Science And China Technology Co.,Ltd Technology focuses on the manufacturing of wafer sorters, life time analysers, wafer & cell vision inspectors, cell sorter and EL testers. Located in China, the company has 100 employees. No further information has been found in the public domain so OST cannot comment reliability of this supplier.

We note that limited information was available for some of the manufacturers. We recommend that further information is provided on the unknown manufacturers. It is unclear what the capacity (pcs) each machinery handles per shift.

5.2 Suppliers of materials and key components

Suntech has provided a Constructional Data Form (CDF) as part of an IEC certification and IEC Factory Inspection by Electronic and Information Technologies (VDE) Prüf- und Zertifizierungsinstitut. The CDF provided by Suntech reports materials and key components provided by several suppliers from various countries worldwide. Several suppliers for a number of the components are detailed in the VDE test report which we consider leads to a lack of uniformity in the production of the modules. The VDE test report does not detail the combinations of each component which would limit the variation in the module production

This section outlines the materials and key components sourced from suppliers from various countries worldwide and used in the manufacturing of the Suntech modules reviewed. In order to produce modules that conform to IEC61215 and IEC61730 standards, the materials used to manufacture the modules must be in certified by an IEC approved certification body (TUV, VDE, UL or similar) and must be included in the Constructional Data Form (CDF) that forms part of the certification.

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We note that the list of components below is very comprehensive; however, we received confirmation from Suntech that the number of suppliers for components used for modules which are sold on the European market is limited. These components are highlighted bold.

Table 19: Suppliers of key components of modules Component Type Supplier OST comments Cell Suntech:STP156M 3BB Suntech See Section 2 Suntech:STP156M LR 4BB Q6LTT3 Hanwha Q-cells Q-Cells is a German manufacturer of photovoltaic cells headquartered in Bitterfeld-Wolfen, Saxony-Anhalt, Germany. Q-Cells established in 1999, was taken over by Hanwha in 2012. OST considers Hanwha Q-cells a reliable manufacturer. I-Cells Motech Motech Industries, Inc. is dedicated to the research, development, and manufacture of high quality solar products and services, ranging from Photovoltaic (PV) cells, PV modules, PV inverters, to PV power systems. OST considers Motech a reliable manufacturer. GIN156M Gintech Gintech Energy Corporation, established in 2005 and headquartered in Taiwan, is a solar cell manufacturer with a 1.5GW total manufacturing capacity. Gintech’s products are distributed to customers in Germany, Spain, Italy, other European countries, the United States, Japan, China, India, Korea and other Asian countries. Gintech exports more than 95% of its products to overseas markets. According to Solarbuzz, Gintech was the world’s 8th largest solar cell manufacturer in 2013. The company produces both poly and monocrystalline cells. OST considers Gintech a reliable supplier.

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Component Type Supplier OST comments NP6M Neo Solar Power NSP is a solar manufacturer specializing in research, Corporation (NSP) development, and manufacturing of high-efficiency solar cells and modules. NSP was founded in 2005. Following its merger with DelSolar in 2013, NSP has become the largest solar cell and module producer in Taiwan. The company has a cell production capacity of about 1.9GW and has 1,720 employees; NSP has the following certification, ISO 9001, 14001, OHSAS 18001 certified by TUV and all products are RoHS compliant. We are comfortable that NSP is a suitable supplier of solar cells. TSM63TN TSEC TSEC Corporation (TSEC), established in June 2010, is a Taiwanese manufacturer specialised in the production of poly, mono-like and monocrystalline solar cells. The company, which ISO9001:2008, ISO14001:2004 and OHSAS 18001:2007 certified, has a current installed capacity of 500MW and has plans for an expansion to an expected capacity of 1GW by end of 2013. No information regarding other major clients of the company was available. D6R Delsolar Delsolar is a solar manufacturer specializing in research, development, and manufacturing of high-efficiency solar cells, modules and PV systems. The company was founded in 2004. Following its merger with NSP in 2013, Delsolar has become the largest solar cell and module producer in Taiwan. Delsolar products are approved by TUV. The company has a cell production capacity of about 1.9GW. We are comfortable that NSP is a suitable supplier of solar cells.

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Component Type Supplier OST comments M-156-3-Fortis Solartech Energy Corp. SEC is a solar cell and PV module manufacturer, established (SEC) in 2005. SEC has 1,000 employees and an annual capacity of 800 MW of solar cells and 30 MW of module production. Information in the public domain about the manufacturer is insufficient and thus OST cannot comment on the manufacturer’s reliability. 3BB DM Tainergy Tech Co. Ltd. Tainergy designs, develops, manufactures, and markets high- performance solar cells. Founded in 2007 an IPO in Taiwan Stock Exchange (TSE) in 16th August 2011. Located in Taiwan, the company has a capacity of 560 MW. No information regarding other major clients of the company was available. Further information on Tainergy could not be found in the public domain. OST cannot comment on the reliability of Tainergy. ISEC 6M Inventec Solar Energy Inventec Solar specialized in research and development manufacturing of multi-crystaline silicon solar cells. The company was established by Inventec Group and WIN Semiconductor as a joint venture in 2010. The company holds the following certification: ISO9001, ISO14001, OHSAS 18001 and RoHS. No information regarding major clients of the company was available, thus OST cannot comment on the reliability of Inventec. M6B3 Sunengine Sunengine specialized in manufacturing and sales of c-Si solar cells and relevant products in the solar industry. Founded in 2010, the company now has a production capacity of 220 MW. We have not been provided with further information about this company. Glass n/a Shanghai Flat Glass Shanghai Flat Glass Co. is a subsidiary of Flat Group with

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Component Type Supplier OST comments Co., Ltd. production facilities in Shanghai, China. The group has passed ISO9001, ISO14001, China Safety Glass 3C, and SPF.U1 grading certifications. Flat Group has been manufacturing low- iron patterned glass since 2006 and OST considers them a reliable supplier. n/a Changshu SYP Special No information has been found in the public domain and no Glass Co. Ltd information about the manufacturer has been provided by Suntech. n/a Changzhou Almaden Changzhou Almaden Stock Co. Ltd was established in PV Glasses Co. Ltd. September 2009 manufacturing ultra-clear low iron patterned glass for the solar photovoltaic industry and solar street lamps. The company occupies 120,000 square metres and currently employs nearly 600 employees. Changzhou Almaden specialises in the production of AR (anti-reflective) glass and TCO (transparent conductive oxide) glass for use in the production of PV modules. Their website states Wuxi Suntech Power Co. Ltd, Suzhou CSI, Jiangsu linyang Solarfun holdings, Hebei yingli solar, China Sunergy Co. Ltd (Nanjing and Shanghai) as customers. We consider Changzhou Almaden Stock Co. Ltd to be an established supplier. n/a Taicang Pilkington China Pilkington Group Limited is a multinational glass manufacturing Special Glass Limited company headquartered in St Helens, UK and a wholly owned subsidiary of the Japan-based (Nippon Sheet Glass Co., Ltd. Group (NSG). The company manufactures a vast range of glass products in most building and automotive product markets of the world. The NSG/Pilkington group is one of the four largest glass

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Component Type Supplier OST comments companies in the world. OST considers NSG/Pilkington to be an established manufacturer. Zhejiang Hehe Glass Co. Zhejiang Hehe Glass was founded in 1991 and specialized in Ltd. developing and trading architectural decorative glass, solar ultra-white glass and deep-processing glass. The company has 3200 employees. The manufacturer has passed ISO9001, ISO14001, OHSAS18001, CE and Zhejiang AAA standardizing behaviour. OST considers Hehe to be an established supplier. Henan Yuhua New Henan Yuhua Guangfu New Materials Co., Ltd. engages in the Material Co. Ltd manufacturing, marketing, and export of solar panel glass products and is based in Jiaozuo, China. The company exports its products to Europe, Japan, and South America. Information on the public domain about manufacturer is insufficient and thus OST cannot comment on the reliability of this equipment. Dongguan CSG Solar Dongguan CSG Solar Glass Co., Ltd. is based in Dongguan Glass Co. Ltd City, Guangdong and was established in 2005. The supplier certified for ISO9001, ISO14001, OHSAS18001, used components with 3C (2007011302240875) and CTC (WT20110701) certification. With a production capacity of 24,000,000 m2, nine years of experience, OST considers the supplier to be reliable. EVA PV-45FR00S Sanvic Inc. Sanvic, established in 1951, focuses on manufacturing and marketing of synthetic resin products and marketing of polyolefin polymer processing machinery. The company has ISO 9001 and ISO 14001 certifications.

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Component Type Supplier OST comments OST considers Sanvic to be an established manufacturer. FC295P/UF/ EXP X-43- STR STR is based in Connecticut, USA and it is an established 14-C HLT / EXPX-43-47 manufacturer of encapsulant for solar application with 3GW of yearly capacity. OST considers STR to be an established manufacturer. RC02B Fabro Information about Fabro could not be found in the public domain and was not provided by Suntech for review. F806 Hangzhou First PV Hangzhou First PV Material Co., Ltd. is based in Hangzhou, F406+F806 Material Co., Ltd. China. Founded in 2003 in China, First PV is the largest supplier of EVA film and backsheet materials to the PV industry in China. The company has ISO 9001 and ISO 14001 and UL (E326347) certifications. With a production capacity of 300,000,000 m2/year, and 12 years of experience, OST considers the supplier to be reliable. R767 Revax Revax is a manufacturer of EVA encapsulation sheet for PV modules. The company has ISO 9001 and ISO 14001 certifications. No information regarding major clients of the company was available. OST cannot comment on the reliability of Revax. 15296+15297 Svec Information about Svec could not be found in the public domain and was not provided by Suntech for review. TF4+TF8 Hangzhou First PV See above. Material Co., Ltd. Backsheet Icosolar 2442 ISOVOLTA Isovolta Group is an international manufacturer of electrical insulating materials, technical laminates and composites and was founded in 1949. The company serves about 20 industries with more than 1,700 employees worldwide.

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Component Type Supplier OST comments Isovolta began the production of backsheets and encapsulation films for PV modules in 1985 with its first product launched in 1988. The subsidiary company, Isovoltaic, was launched in July 2010. OST considers Isovolta to be a reliable manufacturer. PTL 3-38/250, PVL 1000 Krempel Krempel is a manufacturer of electrical insulating material, V solar material, electronic materials and special films and papers. The company has IEC 61730-1 and IEC 60664-1, ISO/TS 16949 and ISO 9001 certifications. Certain types are approved as ”UL Recognized Component“(File No. QIHE2. E312459), TÜV certified (ID 0000033022) and conform to RoHS and REACH directives. OST considers Krempel to be an established supplier. BS-W250-S-FA20 TOYO Aluminum K.K The company was founded in 1931 and later renamed as Toyo Aluminium K.K. It is currently the second largest backsheet manufacturer in the world. Toyo employ over 900 staff and its head office is in Osaka, Japan. They supply other well-known PV manufacturers. The company holds the following certifications: ISO9001, ISO14001, UL, IEC and RoHS. We consider Toyo to be a reliable and experienced manufacturer of backsheet for photovoltaic applications. WPF325PO, BPF325PO Keiwa Inc. Keiwa Inc. was founded in 1948 and currently manufactures optical and solar products. The manufacturer has 450 employees. There is limited information about Keiwa in the public domain, thus, OST cannot comment on the reliability of this supplier. STP-BS-001 and BS-TX- Toppan TPT Toppan TPT is a member of the Toppan Group. The group is 1001 established in printing technologies, information technology,

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Component Type Supplier OST comments electronic and living environment. No information regarding major clients or operations of the company was available. HTK-D330-31 Huitong Information about Huitong could not be found in the public domain and was not provided by Suntech for review. LBS-CF LG Chem Ltd. LG Chem Ltd. was established in 1947 as Lucky Chemical Industrial Corporation manufacturing cosmetics and was renamed in 1995. LG Chem supplies petrochemicals ranging from basic distillates to speciality polymers. Referred to as LG Chemical it is the largest Korean chemical company and is headquartered in Seoul, South Korea. According to ICIS report, it is 15th biggest chemical company in the world in 2011. OST considers LG Chem to be a reliable manufacturer. VTPE1 Taiflex Taiflex Scientific was founded by professionals from ITRI (Industrial Technology Research Institute) in 1997. In April 1999, Taiflex obtained ISO9001 certification. Taiflex has ~800 employees and its primary products are FCCL (Flexible Copper-Cladded Laminate), Cover Layer, PV module back sheet and optical film material. The company has the following certifications, amongst others, ISO 9001, ISO14001, ISO/TS16949, TOSHMS, OHSAS 18001, IECQ HSPM, UL, TUV. OST considers Taiflex to be a reliable manufacturer. Cynagard 09101 Cybrid Cybrid began in 2008 from a high polymer material laboratory. and 100 A The company manufactures photovoltaic materials, electric insulation materials, electric information materials, household appliance materials and motor materials in medical science. Since the end of 2009, Cybrid has supplied over 20 million m2 of backsheet to the PV industry, including Yingli Solar, Canadiansolar and Trinasolar. OST considers Cybrid to be a

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Component Type Supplier OST comments reputable manufacturer. FFC-JW30(White/Black) Jolywood Sunwatt Jolywood (Suzhou) Sunwatt Co.,Ltd is a national high-tech Co.,Ltd enterprise, whichis specialized in the researching, manufacturing and selling PV encapsulation materials. Founded in March, 2008. Jolywood’s backsheet has been certified by UL, TUV Rhineland, JET, SGS, National Center of Supervision and Inspection on Solar Photovoltaic Product Quality (CPVT), ISO9001, ISO14001 and OHSAS18001. OST considers Jolywood Sunwatt to be a reputable manufacturer. LTW-09ST-2 Toray Toray Group focuses on manufacturing plastic and chemicals, fibers & textiles, IT-related products, carbon fiber composite and engineering and environment. Information regarding other major clients or the operations of the company was not available. The manufacturer has limited information on the public domain pertaining to the manufacturing of backsheets. Although having limited information in the public domain pertaining to the manufacturing of backsheets, the extensive top-tier customer list suggests acceptability. BEC-301 Hangzhou First PV See above Material Co. Ltd. APA 3G ISOVOLTA Isovolta Group is an international manufacturer of electrical insulating materials, technical laminates and composites and was founded in 1949. The company serves about 20 industries with more than 1,700 employees worldwide. Isovolta began the production of backsheets and encapsulation films for PV modules in 1985 with its first product launched in 1988. The subsidiary company, Isovoltaic, was launched in July 2010. OST considers this supplier to be

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Component Type Supplier OST comments reliable. dyMat PYE SPV CoveMe CoveMe produces polyester film for photovoltaic modules for 20 years and has more than 200 employees and a production capacity of about 18 tonnes of polyester film. CoveMe is headquartered in Bologna, active since 1965 and with production facilities in Italy and China. It is ISO9001:2008 and ISO14001:2004 certified. All dyMat products have the UL certificate of compliance and the TUV partial discharge certificate. dyMat PYE and dyMat PYE SPV have the TUV InterCert IEC61215 and dyMat PYE SPV is JET certified. From the information available, OST is in general satisfied with the reliability of this manufacturer. Cynagard 245A Cybird, See above. and 215 A GPE-B02 Green Information about Green could not be found in the public domain and was not provided by Suntech for review. TFB-30 Jolywood See above. Frame n/a Xie He Information about Xie He could not be found in the public domain and was not provided by Suntech for review. Kaima Information about Kaima could not be found in the public domain and was not provided by Suntech for review. Hongyibao Electronic Hongyibao Electronic Equipment Co designs and Equipment Co manufactures a series of wafer cleaning and texturing equipment. Now with more than 120 employees and cover a plant area of 7,500 square meters. The manufacturer holds a certification for ISO9001:2000. OST cannot comment on the reliability of the manufacturer.

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Component Type Supplier OST comments Frame adhesive 1527 Tonsan Adhesive. Inc. Tonsan is an adhesive manufacturer located in Beijing, China. Tonsan started production in 1993. The company produces eight adhesives categories and supplies 26 industries. The manufacturer holds a certification for ISO9001:2008, ISO 14001:2004 BS OHSAS:18002: 2007, IS0/TS 16949:2009 by TUV. OST consider Tonsan to be a reliable supplier. HT8258 Dongcheng Dongcheng is a manufacturer of adhesive label sticker, packaging box, graphic overlay, Silicone keyboard and blister packaging, targeting markets in Southeast Asia, North America, Africa, Oceania. Founded in 2007, the company employs more than 500 people. Information regarding other major clients or the operations of the company was not available. OST cannot comment on the reliability of the manufacturer. S56 Otto Hermann OTTO GmbH was founded in 1881 in Berlin as a putty-manufacturing factory. Over the past 130 years it has developed into a specialized producer of sealants and adhesives with an excellent reputation in construction as well as industry. OST considers the supplier to be reliable. Junction Box TL BOX026 and TL Tongling Zhenjiang TongLing Electrics Co., LTD. is located in BOX029 Yangzhong City, Jiangsu and produces solar junction boxes. Most of the products have passed TUV and UL certification. Presently, the factory has become a long-term supplier to many other PV module manufacturers in the Chinese market. The company also exports products to Japan, North America. There is limited information on Tongling in the public domain, we recommend that further details are provided.

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Component Type Supplier OST comments GF20 Cixi Renhe Renhe Photovoltaic Technology Co., Ltd. is a company that specialises in production, R&D, sales and service for PV junction box, connector and cable used for solar PV module. The company has ~1000 employees and the production capacity is around 100,000 sets per day. Renhe products are approved by UL, TUV, IEC, CSA, TUV and ROHS while the company is managed through ISO 9001, ISO 14001 and OHSAS 18001. OST considers Zhejiang Renhe to be a reliable manufacturer. PV-ZH011 Nibo Free Trade Information about Nibo Free Trade Zhonghuan could not be Zhonghuan found in the public domain and was not provided by Suntech for review. RY3 Huber & Suhner Huber & Suhner develops and produces high-quality electrical and optical connections, cable systems antennas and lightning protectors. Founded in 1969 in Switzerland the company has certification for: ISO 9001 and 14001 and IRI Railway solutions. OST considers the supplier to be reliable. Diode STPS1545CG ST Microelectronics ST Microelectronics was founded in 1957, an integrated device manufacturer for Sense and Power, Automotive, and Embedded Processing Solutions. The company has approximately 45,000 employees and owns about 16,000 patents, about 9,000 patent families and 598 new filings. OST considers that ST is an established manufacturer. MBRB1545CT ON Semiconductor ON Semiconductor focuses on energy efficient power and signal management, logic, discrete and custom solutions used in unique design challenges in automotive, communications, computing, consumer, industrial, LED lighting, medical, military/aerospace and power supply applications. The

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Component Type Supplier OST comments company was founded in 1999 as a spin-off from Motorola and has 22, 000 employees. The company has certification for: ISO 14001. OST considers that ST is an established manufacturer. MBRB15H45CT Vishay Vishay Intertechnology founded in 1962 is one of the world’s largest manufacturers of discrete semiconductors and passive electronic components. The company is well equipped to maintain qualifications to a wide range of specifications for Military, IS0 9000, TS 16949, NASA (National Aeronautics and Space Administration Standards) and DIN (German Industrial Standards). OST considers ON Semiconductor to be reliable. MBRS15H45CT and Taiwan Semiconductor Taiwan Semiconductor’s product portfolio to include Analog 15SQ045/10SQ050/SB15 ICs, Power Transistors and MosFETs. Established in 1979. 40LS Taiwan Semiconductor currently employs 2,300 people and is the world's largest dedicated independent semiconductor foundry, with its headquarters and main operations. The company has certification for: TS16949, ISO9001 and ISO14001. OST considers TS to be an established manufacturer. SR3045 Jinan Jinheng Information about Jinan Jinheng could not be found in the public domain and was not provided by Suntech for review. PST4020 Renhe See above. SB3040DY Panjit Panjit is a subsidiary of the Panjit Group, founded in 2002. Panjit focuses on manufacturing of semiconductor, MOSFETs, rectifiers, switches, zener and LED application. Information regarding other major clients or the operations of the company was not available. The company has certification for: TS16949, ISO9001 and ISO14001. OHSAS18001, IECQ QC080000, ISO

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Component Type Supplier OST comments 140641, PAS 2050. OST considers Panjit to be a reliable manufacturer. Connector CL-C4, CB-C4 Huber & Suhner See above. PV-KST4/6II-UR, PV- Multi-Contact Multi-Contact AG was founded 1962 in Basel, Switzerland and KBT4/6II-UR has 4, 000 employees. The company has certification for: ISO 9001, DIN ISO 14001. OST considers MC to be a reliable and experienced manufacturer of connectors. Helios H4 Amphenol Amphenol Corporation is a major producer of electronic and fiber optic connectors, cable and interconnect systems such as coaxial cables for automotive, industrial, mobile network and medical applications. The company was founded in 1932. OST considers Amphenol to be a reliable and experienced manufacturer. PV-ZH202 Zhonghuan See above. 05-6 Renhe See above. Cable-01 Tongling See above. 3153 Tonsan See above.

OST considers the majority of material suppliers to be reliable or established. However, there are many suppliers which leads to a lack of consistency in the product quality. Two cell suppliers have no information in the public domain, while a third cell supplier has limited information about their operation or certification. Nineteen material suppliers have limited information in the public domain and OST recommends that further documentation should be provided.

Suntech has supplied a spreadsheet of the purchased solar cell capacity for the year 2012 and 2013. We note that solar cells were supplied by six different suppliers and used in less than 14.2% of the manufactured PV modules in 2012 and 4.4% in 2013 with the remainder of the cells provided by Suntech.

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OST notes that all the modules reviewed have common suppliers and key components. All the key components listed above are certificated by VDE Prüf- und Zertifizierungsinstitut. Any additional components used or intended to be used in the manufacturing of the Suntech modules (apart from those outlined in Table 19) should be added to the CDF outlined in the VDE Prüf- und Zertifizierungsinstitut list.

Poly-crystalline cells are partly provided internally by Suntech and from other suppliers, and are also listed in the VDE Prüf- und Zertifizierungsinstitut certificate.

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6 Factory Visit Findings

The Suntech module factory in Wuxi was visited on the 12th June 2014 by Martin Cincelli and Gustaf Schuler of OST Energy and Tim Carter of IPSol Energy; also present was Leta Li (Global Product Management, Certification & Assurance Manager) and various representatives from different departments.

The following sections describe the manufacturing and quality processes as witnessed on site including comments on each step.

6.1 Receipt of material from supplier

The various components utilised for the manufacturing of the modules are delivered to the storage facilities located in a building beside the manufacturing lines. On receipt of material each batch of components receives a label with a bar code, indicating the component, the supplier, manufacturing, delivery and ‘use-by’ date, before a number of Incoming Quality Control (IQC) checks are carried out on different samples in accordance with the IQC plan outlined in the sections below.

In case of non-conformities, the batch is rejected and stored within a separate area in the warehouse before it is sent back to the supplier who is required to provide feedback on the nonconforming component. If the sample passes the IQC, either a green sticky label (for the cells) or a stamp (for all other components) is applied on the internal label on each box forming part of the sample/batch and the components are moved to the appropriate storage area (see Section 6.2).

According to Suntech not every component undergoes the IQC program; suppliers which fulfil the following requirements, are considered to have a sufficient in-house QC that another IQC performed by Suntech is not necessary. 1. there is no batch with unconformities for a continuous 3 month period in the production line; 2. there is no lot rejected for a continuous 3 month period during the incoming inspection; 3. the average VLRR (verified line reject rate) can meet the target for a continuous 3 month period; 4. For new product types and inspection items from a supplier the requirements for the IQC can be adjusted individually

Suntech obtains PV cells in addition to their own production from various manufacturers; the cells from their own manufacturing facilities, which are opposite of the module factory, undergo the same IQC program as all other cells. The IQC program has been provided in editable form and is described in Table 20 below.

We were informed that only cells manufactured in Suntech’s own facilities are used for modules sold on the European market.

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Table 20: Checks, inspection method and quality standard of incoming materials Inspection Material Inspection Items Sampling size Criteria and Tolerance Instruments Cell Appearance and figure GB/T2828 Ⅱ AQL:1.5 refer to the technical requirement of Visual/Ruler 1/batch Crystal silicon cell Size n=5, Ac=0, Re=1 refer to the technical requirement of Visual/Vernier 1/batch Crystal silicon cell Caliper/Plug Guage Performance AQL 0.065 n=1250; Ac=2; average EFF ≥ standard +0.05%, electric sorting Re=3 sampling cell EFF≥“standard-0.05%” machine 1/batch do not allow J or J0 Soldering strength n=2, Ac=0, Re=1; ≥ 300g.f Pull Tester 1/quarter Micro-crack & internal defect GB/T2828 Ⅱ refer to cell inspection work instructions EL tester micor-crack AQL 0.065 ( n=1250; Ac=2;Re=3); black heart cell, AQL 0.01n=1250; Ac=0; Re=1) 1/batch Adhesion strength on backside n=2, Ac=0, Re=1 ≥20N.cm Pull Tester field 1/quarter Water boiling n=2, Ac=0, Re=1 1.there is no amass bubble and no Constant 1/week muddy water during testing ,and there is Temperature Water no dropping, no black and yellow on the Boiling Machine; backside field on dry cell after testing; electrical sorting 2.the power decay of cell after water machine boiling is ≤1.5%; Luminous decay n=2；Ac=0；Re=1 mono decay ≤2.0% ; luminous decay

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Inspection Material Inspection Items Sampling size Criteria and Tolerance Instruments 1/week poly decay ≤1.0% tester /Electric Parameter Machine Soldering ability 2 pcs area covered solid busbar ≥75%; visual 1/quarter area covered spot busbar≥90%; Backsheet Width (Roll) 1m×2 Roll 810mm: -1/+2mm，800mm: -1/+2mm Steel Ruler 1/batch 996mm: -1/+2mm，985mm: -1/+2mm Joolywood、LG、Cybrid(KPE):0-2mm, Krempel、Taiflex:0-3mm Thickness 5PCS 0.35mm/±0.03mm， Micrometer 1/batch Cybrid(KPE):0.39±0.03mm, Keiwa:0.345 ±0.035mm, Zhongnanhuitong: 0.33 ±0.03mm, Taiflex:0.368 ±0.03mm, LG, Joolywood:0.30±0.02mm, Krepel: 0.32 ±0.03mm 5PCS Inexact cascade: 1584mm:0/+3mm, Ruler Length (Sheet) 1/batch 810mm:-1/+2mm Accurate cascade: 1574mm:-1/+2mm, 800mm -1/+2mm 5PCS Inexact cascade: 1486mm: 0/+3mm, Ruler 1/batch 996mm: -1/+2mm Accurate cascade: 1475mm: -1/+2mm, 985mm: -1/+2mm 5PCS Inexact cascade: Ruler 1/batch 1960mm0/+3mm,996mm -1/+2mm Accurate cascade: 1949mm-1/+2mm,

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Inspection Material Inspection Items Sampling size Criteria and Tolerance Instruments 985mm -1/+2mm 5PCS Inexact cascade: 1669mm Ruler 1/batch 0/+3mm,996mm -1/+2mm Accurate cascade: 1658mm -1/+2mm, 985mm -1/+2mm Appearance 1m×2 Roll Clean, no Scratch, Creases, Foreign Visual 1Time/batch Bodies on surface Peel strength 3PCS Backsheet and EVA: ≥ 40N/cm Pull Tester 1/2 weeks Weight 10PCS Toyo：483±48g/m², Isovolta：474 - Electronic Balance 1/batch 35/+63g/m², Cybrid：488±40g/m²、KPE ：510±50g/m²，(BPF325P0)： 440±45g/m²，Zhongnanhuitong： 460±46g/m², Taiflex：504±50g/m²，LG： 429±45g/m²，Krempel：460±46g/m²， Joolywood：415±40g/m² 5PCS (Cybrid、Toyo、Isovolta、 Pull Tester Tensile strength 1/batch Zhongnanhuitong、Taiflex、Krempel)） MD、TD≥300N/CM; （Isovolta）MD、TD≥400N/CM，（ Krempel）MD、TD≥350N/CM Elongation 5PCS (Isovolta、Toyo) MD、TD≥100%， Pull Tester 1/batch (Cybrid) MD≥100%、TD≥80%，(Keiwa 、Zhongnanhuitong、LG、Joolywood)

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Inspection Material Inspection Items Sampling size Criteria and Tolerance Instruments MD、TD≥80%，(Taiflex) MD≥100%、 TD≥90%，(Kremple) MD、TD≥85% Self-peel strength 5PCS / 1/batch(before (Cybrid、Toyo、Isovolta、 Pull Tester / COC （before lamination PVDF&PET） lamination); Zhongnanhuitong、Taiflex、Krempel)≥ Report 5PCS / 1/2weeks（after 4N/CM，(Keiwa) ≥4.2N/CM lamination） self-peel strength 5PCS / 1/batch(before (Cybrid、Toyo、Isovolta、 Pull Tester / COC 1.PE&PET before and after lamination); Zhongnanhuitong、Taiflex、Krempel)≥ Report lamination 5PCS / 1/2weeks（after 4N/CM，(Keiwa) ≥4.2N/CM 2.PVDF/PET lamination） KPE before lamination Size Stability 5PCS/1 batch Steel Ruler (Isovolta、Taiflex、LG、Joolywood) MD ≤1.5%、TD≤1.0%，(Toyo, Zhongnanhuitong, Krempel) MD, TD≤ 1.5%，(Cybrid) MD, TD≤1.5%，(KPE) MD≤1.5%, TD≤1.0%，(Keiwa) MD, TD ≤1.0% EVA Width 1m×2 Roll SANVIC:standard:+10/0mm; Steel Ruler 1/batch (STR, First, SVECK):standard :+6/0mm; Fabro:standard:+8/0mm; 1m×2 Roll SANVIC:≥0.45mm; Thickness Gauge Thickness 1/batch STR:0.46±0.05mm; First:0.55±0.05mm; Fabro:0.64±0.05mm;

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Inspection Material Inspection Items Sampling size Criteria and Tolerance Instruments SVECK:0.50±0.05mm 3PCS Peel strength with backsheet (other Pull Tester Peel strength 1/2 Weeks supplier):≥ 40N/cm，> 40N/cm(STR)， > 50 N/cm (First) Peel strength with glass(other suppliers): ≥ 40N/cm，> 40N/cm(STR)， > 50 N/cm (First) transmittance 3PCS Photoelectric 1/batch 280-380nm wavelength, VECK 15296≥ Instrument fog 65%, SVECK 15297≤15%, First 406（P ）≥80%, First 806（P）≤15%；

380nm~1100nm wavelength (other suppliers) ≥90%，First F406≥90%, F806≥85%，SV-15296≥90%, SV- 15297≥85%; Appearance 1m×2 Roll/ NO dirt on surface, no wrinkle, no visual 1/batch bubble, clear coining, no other residue vulcanizing 1part according to work instruction vulcanizing tester 1/batch contractibility 5PCS SANVIC: ≤4%(MD)， STR: < 4%(MD)， Ruler / Oven 1/batch First: MD＜4%, TD＜2%， Fabro:≤7.5%, SVECK:≤3%(MD), ≤2%(TD) Cross Linking Test 5PCS/1Time/batch (SANVIC, Fabro): ≥80%， (STR, First, Cross Linking Tester

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Inspection Material Inspection Items Sampling size Criteria and Tolerance Instruments SVECK):ster:≥70% Junction Size 5 sets refer to SOP ruler/ Vernier BOX 1/batch Caliper Appearance 13 sets refer to SOP visual 1/batch RY3 performance test 5 sets Body sealing insulation resistance: R≥ HIPOT Tester 1/month 400MΩ Box26 performance test 1 set BOX sealing HIPOT Tester 1/batch 5 sets diode positive and negative TEST Multimeter 1/month Frame Size 5PCS refer to SOP Vernier Caliper 1/batch External Diameter Micrometer Universal Bevel Ruler Ruler Appearance 13PCS refer to SOP visual 1/batch Frame hardness 5PCS ＞8HW Sclerometer 1/batch coating thickness(frame) 5PCS ＞12um，and please refer to the GB if Coating Thickness 1/batch the requirement is not listed in the SOP Tester hardness of claw 5PCS ＞8HW Sclerometer 1/batch

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Inspection Material Inspection Items Sampling size Criteria and Tolerance Instruments coating thickness(jump ring) 5PCS ＞8um，and please refer to the GB if the Sclerometer 1/batch requirement is not listed in the SOP connecting property between short 5PCS hang the claw with the weight & hold it Weight frame and claw 1/batch still (AL04-1: 20KG, Others: 10KG) Surface gap 5PCS refer to SOP Platform + Plug 1/batch Guage Camber 5PCS refer to SOP Platform + Plug 1/batch Guage Twist 5PCS refer to SOP Platform + Plug 1/batch Guage Ribbon length 5PCS tolerance:-0.5~+1.5mm Ruler 1/batch width 5PCS tolerance:±0.05mm Micrometer 1/batch thickness 5PCS Ribbon: (0.01 mm / + 0.02 mm) Micrometer 1/batch Busbar: (0.025 mm / + 0.025 mm) Camber 5PCS Ribbon (Take 300mm to measure from Ruler + 10x 1/batch the roll)＜1% Magnifer Ribbon (Fixed dimension) ＜0.7%, Roll(Take 300mm to measure) ＜1% Tensile Strength 5PCS Regular ribbon: Rm≥150MPa pull tester 1/batch Ultra soft ribbon: Rm≥110MPa soft ribbon: Rm≥130MPa

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Inspection Material Inspection Items Sampling size Criteria and Tolerance Instruments Busbar: Rm≥ 170 Mpa Resistance 5PCS ≤0.0235Ω·mm2/m Resistance Tester 1/batch Elongation 5PCS Regular ribbon: 25% Pull Tester 1/batch Ultra sofr ribbon: 15% Soft ribbon: 15% Busbar: 15% Yield strength 5PCS Regular ribbon: 85 Mpa ≤Rp0.2 ≤ 120 Pull Tester 1/batch Mpa Ultra soft ribbon: Rp0.2 ≤ 60 Mpa, Soft ribbon: 60 Mpa ≤ Rp0.2 ≤ 80 Mpa Appearance 32PCS X 2 Rolls refer to SOP visual 1/batch Toughened Length and Width 5PCS Length is between 0 and 2500mm, the Ruler Glass 1/batch tolerance is: 0~ -2mm Diagonal 5PCS diagonal size < 1000 mm, the absolute Ruler 1/batch value of diagonal ≤2mm; Thickness 5PCS 3.2mm/±0.2 Micrometer 1/batch 4.0mm/±0.3 Camber 5PCS Total < 3 mm/m; Line + Ruler 1/batch partial < 0.5 mm / 300 mm Appearance 13PCS refer to SOP visual 1/batch Transmittance 5PCS according to the technical agreement of Transmittance

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Inspection Material Inspection Items Sampling size Criteria and Tolerance Instruments 1/batch each manufacturer transmittance tester judgement Fragment status 1PCS visual 1/month 50 mm × 50 mm area, fragment pieces are more than 40; ARC glass Appearance 13PCS refer to SOP visual 1/batch Film hardness 5pcs ≥3H Pencil Sclerometer 1/month Adhesion tests of film 5pcs ≤5％ Grid Scriber 1/month Transmittance 5PCS 2.5% AR-Coating:≥94.4% Transmittance 1/batch tester

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We have visited the IQC facilities and we have inspected a number of IQC archives which indicated that the inspections were carried out as outlined above. The laboratories where the IQC tests are carried out have also been inspected and appeared to be suitable.

We have not been provided with separate SOPs the table above is referring to and therefore we cannot further comment on these tolerance criteria.

OST has verified the IQC documentation and checked it against industry standards and we consider the set of tests and inspections to be in line with reasonable market practice and industry standards.

6.1.1 Polycrystalline cells characteristics

The cells used in the modules under review which are sold on the European market are exclusively Suntech’s own cells type STP156M 3BB and 4BB. OST was provided with the datasheets of these poly crystalline cells as outlined in Table 21 below.

Table 21: Polycrystalline cells types and characteristics Efficiency Module Cell type Bus- ISC VOC Imp Vmp range (%) FF range type/model /model bars (A) (mV) (A) (mV) of Cell (%) of Cell STP250-20/Wd Suntech: 3/4 8.64 621 8.10 523 17.4% - 78.80% - STP156M 17.5% 79.00% STP255-20/Wd Suntech: 3/4 8.66 623 8.12 524 17.5% - 78.71% - STP156M 17.6% 79.12% STP300-24/Ve Suntech: 3/4 8.66 623 8.12 524 17.5% - 78.71% - STP156M 17.6% 79.12%

We note that the separation of the cells according to a 0.1% efficiency range is stricter than sighted for other manufacturers (generally 0.2% but also at times 0.4%) which should ensure that consistent quality of the cells and also that a closer range of values for Isc, Imp, Voc and Vmp across modules of the same power class is maintained (Section 4). The benefit of such consistency could be found in reduced mismatch losses among strings of modules installed in a solar park.

We consider the above characteristics to be suitable and in line with good market practice and industry standard.

6.2 Components storage

All incoming components are stored in different warehouses at the Suntech factory. The first warehouse we visited is used for the storage of the EVA and the back sheets and the unconformities of these components in a separated area. This warehouse has controlled environmental parameters.

The temperature (T) and relative humidity (RH) are maintained at 25°C and ≤60% respectively. The temperature and relative humidity are checked every 12 hours and recorded on a monthly check sheet kept in the warehouse which is in line with good practice. The temperature and relative humidity during the factory visit were 25°C and 50% respectively. In addition we have

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sighted inspection sheets recording the ambient temperatures for the months of May and June and the entire set of records appeared to be within the required levels.

We note that the RH measurement sensors are not connected to permanent monitoring/alarm system, so if the RH control machines fail the components are in the worst case for 12h in an uncontrolled environment which influences the material quality.

We would expect a monitoring system and a more regular check period for the two parameters to be in line with current market standards.

Suntech has provided the technical document for the EVA in Chinese which states that vacuum sealed packaging is a requirement for the EVA. During our factory visit we could not verify that the EVA is packaged in vacuum sealed wrapping, which should offer additional protection against humidity; however, provided the humidity is maintained within the allowed range, this should not constitute an issue. We cannot however comment on the suitability of the environmental conditions during transport which should be confirmed as appropriate by the EVA manufacturer.

The EVA has a shelf life of 6 months from shipment (according to the product specifications provided). In order to ensure that the EVA is not kept in storage for longer than its maximum shelf life a First In First Out (FIFO) system is in place to encourage effective rotation and utilisation of the component in the storage area.

Figure 18: EVA/ back sheet storage and temperature / relative humidity control

The cells and different module labels are stored in a warehouse very close to the production line with controlled temperature.

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Figure 19: Cell / label storage and cell IQC approval batch

The other components (such as aluminium frames, glass, etc.) are kept nearby in an adjacent warehouse with non-controlled parameters.

Figure 20: Components storage

As outlined above, each box of the batches of components achieving a pass in the inspections outlined in Section 6.1 is labelled with a stamp or a green label and the serial number is recorded and exported into the SAP system for the traceability of the components in the storage warehouses before entering the production lines where a Manufacturing Execution System (MES) control software is used.

We consider the storage facilities to be in line with our expectations.

6.3 Module manufacturing process

The module manufacturing is divided into two separate buildings containing several separate production lines of similar type. One production line consists of four cell stringing machines, four laminators and one framing station with junction box mounting and module testing facility.

We have visited one of the semi-automated lines (automatic tabbing) lines during our visit. All processes, are identical in the different lines, however, machines may be supplied by different manufacturers.

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The factory workshops are operational 24/7. Staff are split in two shifts of 12 hours each with one hour break.

The workshops were under positive pressure to prevent dust ingress; temperature and humidity is also controlled. Protective equipment is worn by all staff, including hair protector, Suntech uniform consisting of trousers and shirt and antistatic gloves and shoes. Visitors are given hair and shoe protectors before entering the workshops which is in line with good practice.

The following sections describe the manufacturing and quality process, as witnessed on site, from preparation of the components through to the finished packed product.

6.3.1 Quality inspection during production

Suntech has provided a number of editable documents which outlined the Quality Control Plan (QCP) whose purpose is to outline the quality inspections to be undertaken during each of the steps forming part of the manufacturing processes. The QCP specifies the control requirements of the company for the inspection and test of the products and semi-finished products. The program outlines the responsibilities for each department and staff. Additional comments on the inspections performed during productions are outlined in the following sections.

Additional documentation was provided, as follows:  A Quality Control Plan outlining, for each production process, the product/process specifications/tolerance, inspection methods and frequencies, staff responsibilities, recording methods and actions upon identification of non-compliances with specifications/tolerances  Inspection standards for a number of processes including EL testing

We have reviewed the documentation above and we have included comments on its contents in the description of each of the production processes in the following sections.

6.3.2 Traceability

In order to assess the traceability of the individual components and materials to the final product, a method using serial numbers is employed. An example of this method was examined for a STP250-20/Wd module which was undergoing final testing during the factory visit. The serial number associated with this module was STP 0B6514305010032414. The serial number can be broken down into five separate parts which all contribute to the overall traceability of the module. These are explained below in the following:  The initial 0 indicates the Wuxi manufacturing facility.  B65 is an indicator of the exact module type  1430501 is the production order  003 is a serial number with that production order  24/14 displays the week/year of manufacture

It is understood that at the time of the site visit, the only way to trace the specific batch or delivery of a component used in a particular production order is to follow through the company’s manual goods-in records. This could be improved by integrating goods-in records with the ERP system.

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6.3.3 Material preparation

Material preparation is undertaken in the same building where the manufacturing lines are located. A complete description of the processes used for each item and the product specifications/tolerances of each item were provided by Suntech and are outlined in Table 22. Specifications and tolerances appear comprehensive; we note however that a number of items refer to meeting various requests, e.g. technology, production sheets, etc. While these appear appropriate, it should be confirmed that staff undertaking these inspections are aware of the specifications of these requests.

During our site visit we sighted the preparation of the EVA and the back sheet which consists of the package removal and the cutting of both components to the appropriate module size. Therefore the components are taken from the warehouse with controlled parameters to the raw material preparation area close to the production lines. According to Suntech the maximum storage time before the material is cut is 12h. The temperature and relative humidity in the raw material preparation area are controlled and checked and recorded regularly. According to the label on the EVA packaging box of SVECK the material has to be stored at a temperature below 25°C; the records of the preparation area showed temperature values of up to 30°C. However, we have sighted written confirmation from SVECK that the EVA can be stored up to 30°C and a RH below 70%.

We have sighted the records for the month of June and confirm that these values were not exceeded. Further records for the previous months should be provided for review to verify the appropriate parameters for a longer term.

Figure 21: Raw material storage area and EVA / back sheet cutting process

We consider the raw material storage area and the raw material preparation process as in line with market standards.

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Table 22: Material preparation description Sample Product/Specification/ Assess and (operator) Sample(QC) Tolerance measure Frequency Frequency size refer to SOP template 5pcs/h 3pcs/12h adjustment Ribbon and ruler curve refer to SOP template 5pcs/h 3pcs/12h tracing, and ruler separated and correct copper leakage not allowed visual 5pcs/h NA tracing, separated and correct Interconnect poor soldering not allowed visual 100% NA tracing, separated and correct non-90° angle not allowed visual 100% NA tracing, separated and correct soldering area ＞70% visual 100% NA tracing, separated and correct EVA dirty not allowed visual 3pcs/4h/mac NA tracing, hine separated and correct more than 12 h after not allowed visual 3pcs/4h/mac NA tracing, opening the package hine separated and correct

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Sample Product/Specification/ Assess and (operator) Sample(QC) Tolerance measure Frequency Frequency wrong material no. not allowed visual 3pcs/4h/mac NA tracing , written by preparation hine separated and station correct appearance clean, no scratch, no yellowish, no visual 5pcs/4h/mac 3pcs/12h return foreign matter hine size refer to SOP ruler 5pcs/4h/mac 3pcs/12h/ma adjustment hine chine Backsheet scratch not allowed visual 3pcs/4h/mac NA tracing, hine separated and correct dirty not allowed visual 3pcs/4h/mac NA tracing, hine separated and correct wrong material no. not allowed visual 3pcs/4h/mac NA tracing, written by preparation hine separated and station correct appearance clean, no scratch, no yellowish, no visual 5pcs/4h/mac 3pcs/12h return foreign matter hine size refer to SOP ruler 5pcs/4h/mac 3pcs/12h/ma adjustment hine chine Cell fragment before not allowed visual 100% NA tracing, unpackage separated and correct Glass scratch on glass L＜5mm,W＜1mm,Q≤4； visual 3pcs/4h/mac NA tracing,

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Sample Product/Specification/ Assess and (operator) Sample(QC) Tolerance measure Frequency Frequency L：5-10mm,W＜1mm,Q≤2； hine separated and L：10-25mm.W＜1mm,Q≤1； correct L＞25mm,W大＞1mm,not allowed； breakage not allowed visual 3pcs/4h/mac NA tracing, hine separated and correct dirty on glass not allowed visual 3pcs/4h/mac NA tracing, hine separated and correct

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6.3.4 Back sheet and EVA preparation

The first process is the preparation of the back sheet and the EVA encapsulation. These components are manually loaded into the cutting machines and subsequently arranged into stacks ready to be used. The material preparation area is located in the workshop in a separate temperature and humidity controlled area. The required levels as given by Suntech are a temperature between 20°C and 30°C and relative humidity below 60%. The environmental parameters of the preparation area are checked regularly and recorded on a check sheet mounted on the wall.

Figure 22: Raw material storage area and EVA / back sheet cutting process

Once cut, the EVA can only reside in the manufacturing area for a short period in order to avoid compromising the material which can lead to the likelihood of ‘browning’ during the PV module’s lifetime. Suntech staff stated that the maximum storage times allowed at this stage is 12 hours; we consider that this period is within market standard for EVA handling arrangements. The opening and cutting times of the EVA are logged and the stack of cut EVA is delivered to each production line when the last stack has been utilised to ensure that the first cut is the first used.

The ‘Quality Control Plan’ content for the preparation of the EVA and back sheet materials is outlined in Table 22 above.

6.3.5 Cell tabbing/soldering and stringing

Suntech use cells from various manufacturers for their modules but for one module only cells from one manufacturer are used. The sticky label with the serial number of each box of cells is scanned and subsequently attached to the digital BOM sheet, which is generated for each module.

The range of efficiencies and other electrical characteristics of the cells can be seen in Section 3 and Section 6.1.1.

We have been provided with the Quality Control Plan outlining the ‘sorting of solar cell’ processes, which is described in Section 6.1.

There are 49 automated tabbing machines from six different manufacturers in the facility visited.

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In the automated lines cells are manually placed into the tabbing machine, ensuring that only cells from the same type are used for the production of one module. The barcode of each box of cells is scanned and added to the digital BOM of each module, guaranteeing the traceability of the component.

Each cell is moved within the tabbing machine via air suckers to minimise stress on the cell material. Each cell is tested with infrared (IR) thermography to check for defects and automatically sorted out if non conformities are detected. Otherwise they are aligned to form the strings of the required length.

Depending on the cell type and the ribbon the cells are pre-heated to approximately 175°C to reduce the thermal gradient through the cell during soldering, depending on the tabbing machine; this is indicative of good practice and ensures that the ribbon is properly soldered to the cells. Smoke from the process is removed via the fume extraction included in the machine.

The heated cells are then placed on a metal guide, which has the following uses:  To ensure the appropriate location of solder on the cell  To ensure the appropriate spacing between the cells  To apply light pressure to the solder onto the cell during the soldering process.

Light weight ceramic hold-down pins are included in the induction solder head to hold the ribbon in place during the soldering process. No additional contact is put on the cells.

We have sighted different tabbing machines working with different soldering temperatures between 215°C and 370°C, depending on the ribbon used. We note that a soldering temperature of 370°C is very high; we have not been provided with the data sheets for the ribbon and can therefore not confirm the appropriateness of different temperatures.

Figure 23: Automatic tabbing/stringing machine

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Figure 24: Automatic tabbing/stringing machine

The control method includes both visual inspections and specific tests to ensure quality of the tabbing is uniform and of a good standard on each of the automatic tabbing/stringing lines. We have not been provided with the SOP referred to for a number of Product/Specification/Tolerance (see Table 23) and thus we cannot comment on the suitability of these specifications.

Visual inspections are carried out on the out-going tabbed cells and strings of the automatic tabbing/stringing stations. Strings are lifted with suckers and checked on the station (Figure 25).

Figure 25: String checks

The Quality Control Plan for the automated tabbing/stringing processes is outlined in Table 23 below. We have not been provided with the specifications/tolerances which refer to the SOP and cannot further comment on the soldering parameters

Apart from the comments above, we consider the control method and frequency outlined above to be sufficiently thorough and in line with good market practice and industry standard.

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Table 23: Automatic soldering / stringing Control method Product/Specification/To Assess and Sample (operator) Sample(QC) Item Control Items lerance measure Frequency Frequency Take actions Pull tester Pull strength >300gf Pull tester NA Once per shift Mark and segregate soldering Welding Quality Every welding point should Visual 100% 8Pcs/1Time/1 Mark and Rework quality Tin area on be covered by tin,and the 2h area must be > 50% deviation in ≤0.5mm(the exposure of Visual 100% 8Pcs/1Time/1 Mark and Rework frontside busbar at each side is 2h soldering counted from the 5th finger line) deviation in ≤0.5mm Visual 100% NA Mark and Rework backside soldering Poor soldering Do not allow Visual 100% 2Pcs/1Time/6 Mark and Rework h Crack Do not allow Visual 100% NA Mark and Rework the distance 1.5~2.5mm Visual 100% NA Mark and Rework between cell scratch on the visible length ≤10mm,the Visual 100% NA Mark and Rework cell number of scratch cells in the same module ≤ 3pcs,the number of scratch in a cell≤1pc

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Control method Product/Specification/To Assess and Sample (operator) Sample(QC) Item Control Items lerance measure Frequency Frequency Take actions automatic automatic according to SOP Visual 1Time/1week/Machi NA Mark and soldering soldering ne segregate parameters parameters soldering soldering according to SOP Visual 2Time/2Day/Machin NA Mark and machine clean machine clean e segregate

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6.3.6 Soldering, EVA and back sheet lay-up

Strings exiting the tabbing machines are then arranged manually on the glass / EVA already prepared (Figure 26).

Each string is re-checked by the workers and thin sticky tape is placed between the strings to hold them in place during lamination. Bus-bar contacts are then placed to join the cell strings which are hand soldered by the operators (Figure 27). At this stage, the batch number of the EVA, the back sheet and the glass is scanned and recorded onto the digital BOM file for traceability of each component.

Figure 26: Manual string layup Figure 27: Bus bar soldering

We have been provided with the Quality Control Plan outlining the ‘Layout and bus bar soldering’ processes, which include visual inspections and other measurements on soldering of the bus bars and layout of glass, EVA and back sheet, as shown in Table 24 below.

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Table 24: Lay up process – Quality Control Plan Control Method Assess Sample(operator) Sample(QC) and Take Items Control Items Product/Specification/Tolerance measure Frequency Frequency actions Appearance Soldering appearance Crack cell, incomplete soldering, Visual 100% 2Pcs/1Time/6 Mark check exposure of busbar, foreign objects etc. h and rework Cell string distance between strings distance is between 1 and 3mm Visual 100% Once per Mark shift and adjust Polarity Polarity of cell string The voltage indicator shows the positive Multimeter 100% Once per Mark movement shift and rework

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We note that right after the layup and before lamination an intermediate EL test is performed on some of the modules which is not mentioned in the previous table. We received confirmation that from July 2014 100% of the modules will undergo the EL test at this stage. We consider the EL test as a part of the lay up process and suggest to update the requirements accordingly.

We consider visual checks on the module from both sides before lamination as market standard. According to the QCP visual checks on the front of the module are performed according to the SOP at this stage (‘middle check’) and unconformities are recorded. We note that we did not witness these checks during our factory visit and were not provided with the SOP of this process.

Should any defect be found at this stage, the actions outlined in the last column of the table above are carried out which we consider suitable. If for example a cell is detected to be defective it is manually replaced with a cell from the same batch.

Figure 28: BOM for traceability of each Figure 29: Polarity check component – barcode scan

Figure 30: EL testing before lamination Figure 31: EL result

Following the layout, the totality of the strings is tested regarding the polarity (Figure 29).

After that the majority (from July 2014 on the totality) of the fully stringed but not laminated modules is mechanically elevated to the EL (Electroluminescence) tester (Figure 30). There are 21 EL testers in total on the lines with more to be installed; most of them are used for inspections

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prior to lamination, the rest for inspections once the module is finished before undergoing flash testing.

The EL testing before the lamination is performed in order to spot unconformities in the material at a point of the production process where defect cells can still be exchanged. Detection of unconformities after lamination result in the loss of the whole module.

We consider the intermediate QC regarding EL testing of the totality of the modules as described above as market standard.

The EL testing quality control is undertaken by a human operator in accordance with an inspection document with allowed/not allowed criteria. We have been provided with a document entitled “EL inspection standard” which details the quality control for the EL testing; we note that pictures of the defects are included both in the document and also located on the EL tester machines to aid the operator in assessing the EL testing results. We have been advised by Suntech staff that all personnel in charge of EL testing are qualified and trained at the machine.

The following table outlines the checks that are included in the EL inspection standard document. Although no documentation was provided, Suntech has specified that the EL inspection standards outlined in Table 25 refers to the EL testing post-lamination while none of the defects described are allowed pre-lamination. If a defect is identified at this stage, then the defective cell is removed and the module is reworked. Suntech has stated that the defective cell is replaced with a cell from the same manufacturer with the same efficiency and colour.

We note that minor defects are generally allowed post-lamination and consider the list below to be exhaustive and in line with market standard. In addition we point out that, as described in Section 4.1.3, no significant micro-cracking was evident in the modules tested by IPSol which were randomly selected by OST.

Staff informed us that the EL camera is inspected on a daily basis. Additional maintenance schedules were not provided for review. It should be confirmed that the maintenance frequency and checks are in line with the manufacturer’s guidelines.

Pictures files of each module taken with the EL machine are saved and linked to the barcode of each module.

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Table 25: EL inspection standard- post lamination Item Defect Description Criteria Example of defect 1 Dark cell Not permitted

2 Cell micro crack Not permitted if number of cells with micro crack > 3 per module

3 Crack – Edge Not permitted if > 5% of cell area inactive and if > 3 cells / module affected

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Item Defect Description Criteria Example of defect 4 Crack – within cell Not permitted if > 5% of cell area inactive and if > 3 cells / module affected

5 Cell – parallel (run through the Not permitted if > 5% of cell area inactive and whole cell) if > 3 cells / module affected

6 Cracks – crossed together Not permitted

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6.3.7 Lamination

92 laminators from four different manufacturers are installed in Suntech’s production facility to set the EVA. Depending on the EVA used for the module the lamination process is set to different pressures, temperatures and times for vacuum and air inlet process. The parameters were determined empirically and are as follows:  Vacuum: Time: 270s < t < 290s, Temperature: 145°C < T < 147°C  Air inlet: Time: 50s Temperature: 145°C < T < 147°C  Vacuum pressure: 850mbar

We note that these parameters are confirmed each quarter by choosing modules and performing certain reliability tests on them. Suntech has confirmed that no unconformities due to the lamination were found so far. OST considers this methodology as a satisfactory method to regularly verify these parameters.

Figure 32: Laminator and monitoring system

The laminators are installed with condensate removal pumps to expel the fumes given off by the EVA lamination. We were informed by staff that maintenance on the laminators is carried out regularly weekly, monthly, semi-yearly and yearly. We have not sighted any maintenance logs during the visit and we note that it should be confirmed that the maintenance frequency and checks are in line with the manufacturer’s guidelines.

We have been provided with the Quality Control Plan outlining the ‘Lamination’ processes, as outlined in Table 26 below. The list in the table below includes a number of checks undertaken on the laminators parameters (e.g. Temperature and Leakage), specific tests that modules undergo following lamination.

According to Suntech certain tests like a pull test between EVA and the glass (quarterly) or the silicone filling of the junction box for the adhesion between junction box and back sheet (100%) are performed regularly; however, are not included in the Lamination – Quality Control Plan. Also appearance tests are performed according to the ‘self-inspection for lamination process’ in order to detect defects like cell crack, bubbles dirt and de-lamination. Any defects found during the self- inspection are recorded by the operator. We consider the tests performed at this stage as stated by Suntech as satisfactory; however, we note that these tests and their quality criteria should be added to the QCP.

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We note that after the lamination process with the laminator from Meier Group the back sheet of the module exhibited some inconsistencies in its surface (Figure 33). Suntech explained this phenomenon during the factory visit, the reason being the nature of the laminator. Suntech confirmed that quarterly reliability tests on the module show no impact on the module performance.

Figure 33: Inconsistencies in the back sheet after lamination

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Table 26: Lamination - Quality Control Plan Control Method Sample Product/Specification/ Assess and (operator) Sample(QC) Item Control Items Tolerance measure Frequency Frequency Take actions Lamination Daily check Refer to the check items & Checksheet Once per shift Once per shift Mark and running status parameters adjust Dynamic temperature Refer to process parameters Dynamic Once per NA Mark and temperature quarter adjust tester EVA Cross linking ≥70% Cross linking NA Once per 7 Mark and tester days segregate

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6.3.8 Framing and junction box assembly

Trimming of the modules is done manually in an area adjacent to the laminators.

A factory worker places silicone glue in the aluminium frames which are then placed on the corners of the modules and inserted in a press. Following this the frame is auto-compressed, excess glue, the frame protection foil is removed and the junction box is applied, sealed and soldered manually.

The Suntech production facility has 53 framing machines; according to the factory staff the framing is the bottle neck of the module production.

Figure 34: Frame gluing Figure 35: Junction box assembly

The manual assembly of the junction box is common within large PV module manufacturers. To seal the junction box it gets filled up with silicone glue after its assembly (potting).

We have been provided with the Quality Control Plan outlining the ‘Framing’ processes, as outlined in Table 27 below. We consider the checks and tolerances for framing and junction boxes described below to be adequate and in line with market standard.

After the framing and junction box assembly the modules are stacked upside down on pallets and stored for curing for at least 6h at a controlled temperature of 25°C in the production hall. We consider the curing period to be sufficiently long and in line with market standards.

Table 27: Frame quality control plan Module frame Criteria 1.1 Tolerance of physical length (L) / ± 2mm of specified L / W on the data sheet width (W)

1.2 Tolerance of diagonal / square (D) ± 4 mm of D of specified L / W on the data sheet calculated with the formula: 퐷 = √퐿2 + 푊2

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Module frame Criteria

1.3 Sharp corners / burrs Not permitted 1.4 Frame deformations (concave) depth<2mm, length<10mm, area<2mm² 1.5 Frame edge misalignment / gap front side: <0.3mm,

outboard part for backside drainage holes: <0.6mm,

inboard part for backside drainage holes: <0.9mm

1.6 Frame scratch The surface of scratch does not have the sense of touch: <50mm (did not show the alloy layer); Not permitted (show the alloy layer)

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6.3.9 Module cleaning and testing

After the curing period the lid is put on the junction box and the modules are manually lifted to the EL test machine, thereby being turned. Before the EL tests are performed the modules are cleaned with alcohol and the remaining frame protection foil is removed. We note that the modules are cleaned horizontally which requires extra care from the factory workers to not damage the modules. It appeared that the staff is aware of that.

Figure 36: Module cleaning, EL testing Figure 37: EL picture machine

Following the cleaning, the final EL testing is undertaken on 100% of the modules in one of Suntech’s 21 EL test machines with the tolerances outlined in Table 25 in Section 6.3.6 which as stated previously we consider appropriate and in line with our expectations. Before each electrical test the barcode of each module is scanned in order to save the test results to each module serial number.

According to the outcome of the EL testing each module is grouped by qualified staff into different grades, A1, B and rejected. We were informed that only grade A1 modules are sold on the European market. According to company staff, the rate for grade B modules is very low (<0.1%) and the rate for rejected modules is even lower.

For more information about the EL test and the quality control parameters please refer to Table 25 in Section 6.3.6.

After the EL test, a high potential test is performed on the modules where a voltage of 3600V is applied in order to ensure that the module is sufficiently well insulated between current carrying parts and the frame.

The last stage is a flash test; Suntech uses Class ‘AAA’ solar simulators (Section 5.2) which are calibrated every four hours. As common practice calibration is in accordance with the procedure below:  Primary module is calibrated and certified every year  Secondary module is calibrated every three months using the primary module  Flash tester is calibrated every four hours with the secondary module

The scope and frequency of final testing is comprehensive, with all IEC mandatory and recommended tests performed on 100% of modules. The equipment was correctly used and

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properly calibrated. A third level of reference module (potentially to perform ‘round robin’ type checks across all flashers) could be introduced to improve flasher calibration, but the weekly checks on the reference module witnessed showed no greater than 0.2% change in Pmpp since its previous calibration.

The calibration procedure is in line with our expectations and with current market standards.

Standard Test Condition (STC) specifies a cell temperature of 25°C and an irradiance of 1,000 W/m2 with an air mass 1.5 (AM1.5). While the second and the third parameters are achieved within the flash tester, common practice before flash testing is to store the modules in a room at constant temperature of 25°C in order to achieve the required STC condition.

All above described tests are performed in the production hall which has a controlled temperature of 25°C.

Table 28 below outlines the ‘Testing – Quality Control Plan’.

Figure 38: Flash tester and resulting module IV curve

Figure 39: Controlled temperature in the production hall

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Table 28: Electrical testing quality control plan Control method Sample Product/Specification Assess and (operator) Sample(QC) Process Item Control Items /Tolerance measure Frequency Frequency Take actions Electric Isolation & Isolation 3600V Isolation & 100% Once per Mark and Paramater Grounding testing Grounding tester shift segregate Testing tester Grounding 30A Isolation & 100% Once per Mark and testing Grounding tester shift segregate Flash tester Calibration Current: ±0.8% 2nd standard NA Three times Mark and Power: ±0.3% module per shift segregate Temperature 25±2℃ IR sensor 100% Three times Mark and per shift segregate EL Testing EL tester EL quality Refer to EL criteria EL tester 100% Once per Mark and day segregate

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6.3.10 Final inspection

At this point an inspection on the finished modules is undertaken. Table 29 below outlines the inspection on finished products shown in the Final Inspection - Quality Control Plan provided. All modules are carefully inspected under an illumination of not less than 1,000 lux.

We consider the set of tests and inspections to be in line with good market practice and industry standard. During our visit we did not witness any modules being rejected during these final visual checks.

We note that during our visit the average final inspection time per module was between 5 and 10s; we do not consider that all quality controls can be achieved in this time. However, Suntech has stated that 100% of the modules undergo inspection after each production step before the module is passed on to the next stage and therefore the given time for the final check is sufficient.

We consider this comment as valid; however we recommend that the scope for the final inspection is updated to reflect this.

Table 29: Final inspection – quality control plan Item Criteria Module frame 1.1 Tolerance of physical length (L) / ± 2mm of specified L / W on the data sheet width (W)

1.2 Tolerance of diagonal / square (D) ± 4 mm of D of specified L / W on the data sheet calculated with the formula: 퐷 = √퐿2 + 푊2

1.3 Sharp corners / burrs Not permitted 1.4 Frame deformations (concave) depth<2mm, length<10mm, area<2mm² 1.5 Frame edge misalignment / gap front side: <0.3mm,

outboard part for backside drainage holes: <0.6mm,

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Item Criteria

inboard part for backside drainage holes: <0.9mm

1.6 Frame scratch The surface of scratch does not have the sense of touch: <50mm (did not show the alloy layer); Not permitted (show the alloy layer) Solar cells 2.1 Cracked cell Visible crack of one cell in one module: Not permitted 2.2 Cracked cell – corner of the cell Maximum size ≥ 2 x 2mm not permitted; Triangular type is not permitted. 2.3 Cracked cell – edge of the cell Maximum size ≥ 10 x 0.5mm not permitted; Triangular type is not permitted. 2.4 Solar cell alignment Cell-Cell Distance between two cells: 1~3mm; Distance between two strings: 1~4mm. (refer to the Appendix) 2.5 Solar cell alignment Cell-Module Distance between the cell edge and the frame inner edge: ≥ 4mm. (refer to the Appendix) 2.6 Screen print failures Maximum grid finger interruption: ≤ 1mm, quantity≤ 10 per cell. 2.7 Soldering / Stringing Maximum displacement of soldering position: ≤ 0.8mm 2.8 Cell colour Not permitted to mix dark and light cell colors in one module

Laminate 3.1 Bubbles On the cells: less than 3 bubbles ≤ 2.5mm diameter permitted. > 2.5mm diameter not permitted

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Item Criteria 3.2 Delamination Not permitted 3.3 Foreign items inside the laminate ≥ 4mm² area not permitted

3.4 Delamination on the back sheet Not permitted 3.5 Damage of back sheet Damage of the back sheet layer not permitted 3.6 Dents Allowed for dents with the depth >0.3mm: quantity< 15 per module, area ≤ 100mm². Glass 4.1 Scratch on the glass surface surface scratch with a length of ≥50mm not permitted

4.2 Broken glass Broken glass without external impact not permitted Sealing 5.1 Silicone residue on glass surface ≥ 5 spots per module with diameter >5mm not permitted Junction box 6.1 Junction box detached Gap between Junction box and back sheet not permitted 6.2 Junction box misplaced Junction box placed in parallel to the upper frame; oblique placing with the different distances between the two edge body of J-box top-side to the top frame edge is ≥ 8mm, not permitted 6.3 Damaged cables / connectors Not permitted 6.4 Cable length tolerance ± 10mm of specified length on the data sheet 6.5 Incorrect connectors 2 connectors of same polarity on one module not permitted

6.3.11 Packaging

After the final inspection the modules receive their nameplate label with the module data according to the flash test results. During the visit the modules produced were the STP 250- 20/Wd. According to the flash test result the modules were stacked on different piles for 245Wp, 250Wp and 255Wp and labelled with the corresponding nameplate label.

Flash tested modules are labelled and then stacked onto pallets horizontally before being stacked vertically in boxes of 28 adjacent to the final inspection area. We note that stacking the modules

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horizontally can lead to damages and we suggest that Suntech should consider stacking the modules directly in a vertical position to reduce the risk of damage.

Figure 40: Stacked and packed modules

We were provided with a QCP for packaging which states that appearance and the labels are checked for every package on 100% of the packages.

We note that the ‘requirements’ outlined above should be better defined as we consider this level of detail will not inform the operator on the level of accuracy required. However, Suntech has stated that a detailed inspection document is issued in their IBMS for packaging which includes the inspection items, inspection frequency, inspection tool, and judgment criteria. Additionally all responsible staff is trained on the job and informed about the quality requirements of packaging. OST has not been provided with this document for review and as such cannot comment on the suitability of the inspection terms.

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6.4 Test facilities at Suntech

The Suntech internal Test Laboratory is ISO 17025 accredited by CNAS with its scope of accreditation encompassing the whole of IEC 61215, IEC 61730 and UL 1703. It also carries CSA certification for UL 1703 and is in the VDE Test Data Acceptance Program for IEC 61215 and IEC 61730. The laboratory can also perform a salt mist test to IEC 61701 and junction box testing to IP65 and IP67. EVA cross-linking and rip-off tests are undertaken in-house. The company has four outdoor test sites, two in Wuxi, one in western China and one in Phoenix, Arizona.

Calibration of production flash testing reference modules from primary reference modules is undertaken on the laboratory’s AAA flash solar simulator, as is assessment for drift. This device is due to be upgraded to a Pasan A+A+A+ in the near future. PID testing is undertaken at both 60°C/85%RH and 85°C/85%RH, for both R&D and production QA purposes. Four modules per month are sampled from production for PID testing, with consistent passes at the 60°C/85%RH level as demonstrated by the records provided.

16 modules of two different types are sampled from production per quarter to go through damp heat, TC200, humidity freeze and hotspot testing. The Q1 2014 Reliability Test Report (ref. TC- 14-C-0037, issued 24th April 2014) was provided in evidence. It was stated that this is now being increased to 24 modules of 3 types per quarter. The company also performs ‘double IEC’ chamber testing i.e. TC400 etc. as well as chamber testing to destruction, for R&D purposes.

The Suntech Test Laboratory is comprehensively equipped and carries a significant amount of third party accreditation according to ISO 17025, as well as R&D and pre-qualification testing. Samples are routinely taken from production for PID, accelerated lifetime and hotspot testing. This is a significant asset in terms of the QA/QC provision within the Suntech production facility and is of a gold standard level for the industry.

No record or judgement is made with respect to defects other than microcracks and dark cells visible with electroluminescence imaging, such as finger interruptions and cell mismatching. Broadening the Electroluminescence Test to incorporate mismatching and cell production defects would improve the effectiveness of this step in controlling quality, especially when third party cells are in use.

We consider the testing facilities of Suntech to be appropriate and above market standards. We note that not many manufacturers can offer this thorough in-house testing and thus this is a positive indication of their QA processes.

6.5 Training

As part of Suntech’s 2014 training plan, we understand that production operatives are trained on specific technical tasks against the relevant standard operating procedure. Suntech has allocated three members of their staff to perform the manufacturing line training. These personnel are understood to be ‘trained trainers’ that have been assessed and deemed competent to perform this function. An automatic solder training report for one particular operative was provided in which details of the individual tasks assessed against were outlined. This report was also noted to be signed off by the trainer, line-manager and HR representative.

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In order to maintain the required level of competency, an annual retraining program, incorporating an examination of knowledge and skills is to be carried out. The frequency of training and assessment of EL operatives is to be increased to once a month. It is understood that the company does not utilise contract or temporary staff, resulting in no separate provision being made in this regard. Suntech has a comprehensive and well-functioning quality system with a good standard of record keeping. Training and competency assessment of production staff is well organised and seems to be in good order. Evidence of this was displayed through numerous documents provided by Suntech such as an email notification of the June 2014 training where signatures of all attendees and instructor were present.

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7 Acceptance in the Marketplace

7.1 Project experience

The Manufacturer provided details of projects that feature modules with similar characteristics to the three models under review. The table below shows a non-comprehensive list of PV plants that feature modules with similar characteristics to those analysed in this report. These projects are detailed in Table 30 below.

Table 30: Project experience list - Suntech Power Location (MWp) Model of module Completion Date Europe Greece Piraeus 8 STP240-24/Wd Aug. 2013 Spain Valdecaballer 5.15 STP175S-24/Ab 2008 os Germany Brandenburg 24 STP270-24/Vd 2010 Germany Kraichtal 0.00817 STP190S-24/Ad+ 2011 Germany n/a 26 STP240-24/Wd 2012 Netherlands Amsterdam 0.1 STP280-24/Vd 2012 Italy Lombardy 0.389 STP205 - 18/Ud 2011 Italy Viarolo 3.8 STP280-24/Vd 2011 Romania n/a 39 STP245-24/Wd 2012 North America USA Arizona 52 STP290-VRM-1, Dec. 2013 STP300-VRM-1 USA Nevada 14 STP175S-24/Ab 2007 USA Colorado 8 STP265-24/Vb 2007 USA Arizona 52 STP290-VRM-1, 2013 STP300-VRM-1 Mexico Baja California 38 STP230-24/Ve Jun. 2013 Sur Asia and Oceania Japan Kumamoto 37.5 STP185S-24/Adb+ Jan. 2011 PRF Japan Kumamoto 0.334 STP290-24/Vd Feb. 2013 PRF Japan Ibaraki PRE 1.7 STP245-20/Wd Aug. 2012 Japan Fukuoka PRF 1.75 STP290-24/Vd Nov. 2012 Japan Fukuoka PRF 6.54 STP290-24/Vd Dec. 2012 Philippines Manila 0.571 STP280 - 24/Vd May. 2012

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Power Location (MWp) Model of module Completion Date Saudi Riyadh 3 STP280-24/Vd Apr. 2013 Arabia Israel n/a 11 STP300-24/Ve Apr. 2013 Thailand Ayutthaya 50 STP295-24/Vd Aug. 2013 South n/a 40 STP300-24/Vd Apr. 2013 Korea Australia Bundaberg 0.03 STP250-24/Wd Oct. 2012 East China Gulang 50 STP300-24/Vd Jun. 2013 China Suzhou 10 STP250-20/Wd Jun. 2013 China Gansu 20 Pluto275-Vdm, STP280- Mar. 2013 20/Wd China Qinghan 10 STP180-24/Ad Dec. 2011 Africa South Africa Northern 50 STP290-24/Vd Apr. 2013 Cape South Africa Northern 50 STP290-24/Vd Apr. 2013 Cape

We note that the significant amount of Suntech modules installed on large scale PV plants globally confirm the acceptance within the European and global market.

Suntech has not provided OST with the details of any project in progress.

7.2 Bankability

Table 31 below outlines a list of projects with the relevant bank finance counterparties utilising Suntech modules. No details about which modules have been installed or indications about the due diligence process for the achievement of the bankability have been provided by Suntech.

Table 31: Projects experience list - Suntech Bank / Financial institution Country of project UniCredit SpA Italy Banco Santander SA Spain Deutsche Bank AG Germany KFW Germany Banca Infrastrutture Innovazione e Sviluppo Italy MPS Capital Services Italy Unicredit Mediocredito Centrale Italy

We consider that the above list of projects and bank finance counterparties is indicative of acceptance by a few Europeans countries, however it is not indicative of the general bankability of Suntech modules in the European and global marketplace.

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7.3 Contractors and Developers

Suntech has also provided a list project locations and EPC Contractors and Developers who have used their modules. The list includes the following:

Table 32: Table of EPC Location EPC/Developer Europe Germany n/a2 n/a Romania n/a n/a Greece Piraeus Green Energy Spain Valdecaballeros SunCarrier a+f GmbH Germany Brandenburg Solarhybrid AG Germany Kraichtal Wirsol Solar AG Netherlands Amsterdam Oskomera Solar Power Solutions Italy Lombardy SunSystem Spa Italy Viarolo Enerray S.p.A. North America USA Arizona Zachry3 USA Colorado Dev.: SunEdison USA Nevada n/a USA Arizona EPC: AMEC Mexico Baja California Sur n/a Asia and Oceania Japan Kumamoto PRF n/a: NTT Facilities, Inc. Japan Kumamoto PRF n/a: Shin-Idemitsu Co.,Ltd Japan Ibaraki PRE n/a: West Holdings Corporation Japan Fukuoka PRF n/a: Shibaura Tokki Japan Fukuoka PRF n/a: Shibaura Tokki Philippines Manila n/a: Propmech Corporation Saudi Arabia Riyadh EPC: Phoenix Solar Israel n/a n/a Thailand Ayutthaya n/a: Bangchak Solar Energy South Korea n/a n/a Australia Bundaberg n/a: Scott Burke Electrical Pty Ltd. East China Gulang n/a

2 Suntech has not provided a location or name of EPC/Developer 3 Suntech has not made clear whether the listed company is an EPC or a Developer

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Location EPC/Developer China Suzhou n/a China Gansu n/a China Qinghan n/a Africa South Africa n/a Siemens

Suntech has also provided a list of EPC contractors, developers and distributors who have used their modules. The list excludes the project location.  IBC Solar AG  Enerparc AG  Krannich Solar GmbH & Co. KG  S.A.G. Solarstrom  Energiebau Solarstromsysteme GmbH  Biosar Energy S.A.  Seraphim Solar System GmbH  Cujmir Solar S.R.L.  Sun System S.p.A  Studina Solar S.R.L.  Rexel Renewables  Parabel AG  Enerpoint S.p.A  Vanju Mare S.R.L.  Viessmann Photovoltaik GmbH  Potelu Solar S.R.L.  FR-Frankensolar GmbH  Alternergy Limited  Kuttler Verwaltungs GmbH  BeBa Energie GmbH & Co. KG  Grupotec Tecnologia Solar,S.L.  SunSwitch S.A.  Bihler GmbH & Co. KG  S.P. Green Energy Ltd.  Tritec Logistics GmbH  Natec Sunergy BV  Waxman Energy Ltd.  Sistemi Fotovoltaici.com Srl  Mitsubishi International GmbH  Phoenix Solar AG

The above EPC list is indicative of general acceptance of Suntech modules.

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8 Operational Performance

Operational data for one plant where similar Suntech modules (STP XXVe 250, STP XXVe 260, STP XXVe 270, STP XXVe 280) are installed have been provided by Suntech. The plant in Puertollano, Spain, has an installed capacity of 52 MWp. The Puertollano project by Renovalia, was divided into 10MW developments. Subsequently, the performance data from Puertollano, was collected from a single 10MW section of the plant.

Suntech has provided the operational performance data for the Puertollano PV plant in the form of a questionnaire from KPMG, answered by Renovalia. This operational performance data related to the period of January 2009 to December 2009, and the report provided includes energy production, estimated energy production and Performance Ratio (PR) data.

The details relating to the calculation of the PR and the irradiation data for the Puertollano plant were not provided. It is unclear whether irradiation data is recorded using reference cells or pyranometers. OST would typically expect irradiation to be measured using secondary standard pyranometers.

Table 33: Performance Ratio (PR) Module Days Expected Actual Output Difference PR in Output (kWh) (kWh) 2009 STP250, STP260 365 18,424,518 16,897,631 9.04% 85.6% STP270, STP280

The PR data suggests acceptable performance for this specific plant that uses Suntech modules. However, specific information about the site such as metrological factors, location of the meters, technology used including transformers and design of the plant will all affect the overall performance of the plant. We note that we cannot confirm that the irradiance sensors are installed appropriately and giving reliable data, so the evaluation of the data cannot provide clear conclusions on performance of Suntech modules.

We also note that the performance data of the plant is a result of the performance of different systems. The installation’s annual target was 78.7% and it achieved 85.6%. Although modules largely contribute to the final performance, in absence of DC tests, and more detailed operational data, we can only acknowledge that the plant has been operating above expectations.

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9 R&D

Information on the R&D projects by Suntech has been provided, however, no specific documentation on the R&D activities of Suntech has been provided. We understand that Suntech has been involved in 25 research projects over the past three years. Suntech is engaged with a leading institution for silicon solar research at the University of New South Wales in Australia. Suntech and the University of New South Wales jointly-developed PERL cell technology, now employed on all Suntech Pluto cells and Hi-Performa modules, which set the 2009 world record for solar conversion efficiency.

Suntech has provided a spread sheet outlining their recent research projects. We understand that in order to improve the efficiency of PV modules, the following developments are being researched:  a-Si/micro-Si tandem thin film solar module development  Rear surface silver and aluminium paste development  Over 20% efficiency selective emitter solar cells base on laser doping industrialization set technology  Sheet resistance uniformity

The roadmap of the new generation low cost high efficiency crystalline solutions to be adopted by the manufacturer does not confirm actual feasibility of the technical improvements and/or achievement of the declared goals within a specific timetable.

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10 Warranties and Guarantees

10.1 Limited warranty for PV modules

Suntech Power has provided two warranty documents; one that applies globally and a second that applies only inside the European Economic Area and Switzerland. OST has reviewed the warranty documentation which applies in Europe, entitled ‘2014 Suntech standard warranty-- Europe’. We note that the warranty document is applied generally to Suntech STP, Pluto and MSZ PV module series. The warranty covers a wide range of Suntech’s modules and is valid for modules dispatched from and on the date of 1st January, 2014 and produced between 1st and the 52nd calendar week of the year 2014.

The Manufacturer provides two types of warranties to its customers:  10 year limited product warranty  25 year limited peak power warranty

The Warranty Start Date is the day of sales or 12 months after modules dispatch from the Suntech factory, whichever occurs earlier. Key points of the warranty conditions are described below.

10.1.1 Limited product warranty

Suntech offers a 10 year material and workmanship warranty that guarantees that all PV modules are free from material defects.

If a module is found defective in material, Suntech will, at its sole discretion, repair or replace the module by a functional module of the same type. If Suntech no longer manufactures the respective module type, Suntech will either supply a functionally equivalent module of the same or higher power of a different type or refund the owner with the actual market price.

Any warranty works carried out or payments made do not extend the warranty period. The limited product warranty is in line with current market standards.

10.1.2 Limited peak power warranty

Suntech provides a standard linear performance warranty discussed below. The output power of the Suntech warranty is based on the respective datasheet Peak Power at STC4.

Suntech warrants, as a voluntary, independent performance warranty, that each PV module will exhibit a power output of no less than:  97% of nominal power output for the commencing year,  0.7% maximum decrease from the module’s nominal power output per year, for years two through twenty-five, ending with the 80.2% in the 25th year after the defined warranty start date.

4 (a) light spectrum of AM 1.5, (b) an irradiation of 1,000 W/m2 and (c) a cell temperature of 25°C, at right angle irradiation

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If the output power of the module is below the adjusted nominal power due to defects in material, Suntech will either repair or replace the module by a functional module of the same type. If Suntech no longer manufactures the respective module type, Suntech will either supply a functionally equivalent module of the same or higher power of a different type. Suntech will also compensate the proven lost profits of the defective module from the day of acknowledgement against Suntech.

We consider Suntech’s provision to compensate for lost profit of the defective module to be above common marketplace practice. We also consider the linear performance warranty to be in line with current market standards.

10.1.3 Warranty exclusions and limitations

Suntech’s warranty only applies to modules under proper use, keeping with the operating conditions and installation specified in the applicable module datasheet and installation guide. Warranty claims shall be filed in writing to Suntech within the applicable warranting period, without exception.

The Manufacturer’s Warranties will not be applied to any modules which have been subjected to:  Mechanical, electric or thermal overload, not in accordance with the conditions of the respectively applicable datasheet and guide.  Use of unsuitable connectors or service‐parts, inappropriate modifications of the PV‐ module.  Incidences caused by the acts of God, such as falling trees or branch breaks, floods, landslides, violent storms, fire and animals.  Theft, wilful damage or vandalism.  Impairments caused by external effects, such as dirt stains, smoke, damages caused by salt and by chemicals not explicitly authorized for use on module.  Power outage, surge voltage, lightning, accidental breaking of the PV-module.

Warranty claims will not be honoured if the type or serial number of the modules have been altered, removed or made illegible.

We understand that the above exclusion of impairments caused by salt, refers to direct module contact with salt, beyond conditions under the IEC61701 ed. 2, severity 1 test, which the modules under review have passed. Warranty exclusions and limitations are generally in line with our expectations.

10.1.4 Claims

To claim a warranty service the customer shall report to Suntech within 10 weeks after becoming aware of the circumstances that establish a warranty case. The report shall be in writing, sent by email or fax, and shall include the following:  The name and address of end customer, installer and respective seller.  A copy of the purchase agreement or installation agreement.  A copy of the periodical maintenance reports required by regional regulations or legal requirements and acceptance protocol of hand over after the installation was finished and the system connected to the grid with all relevant measured system data.  The module type, serial number(s) and quantity.  Address of place where PV modules have been installed.

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 A description of the problem; with images in relation to material defects and information on the PV-generator, inverter and circuitry.  The expected warranty performance and reason for claim.

The return of any module(s) will not be accepted unless prior written authorisation has been given by Suntech. In a valid warranty claim, Suntech will cover costs associated with testing, dismounting, transport, repair and mounting not exceeding average regional market costs. we consider Suntech carrying these costs in the event of a warranty claim places it at the higher end of current market practice Any replaced modules, which have further use, shall become the property of the Manufacturer for disposal.

Claims will be deemed invalid and will not be processed if they are not received within the applicable warranty period.

OST notes that the documents required to file a valid claim may make the claim process complex for small or micro scale standalone project owners. Such standalone projects may not have installation agreements, maintenance report and measured system data which are associated with a grid connected PV plants.

10.1.5 Various

Suntech’s warranty terms do not apply to PV modules marked as “Grade A” or “Grade B” on the nameplate; for these kind of modules special warranties apply which have not been reviewed in the scope of this report. The warranty terms apply only to the end customer.

Should a dispute arise over a warranty claim, an independent testing body such as Fraunhofer ISE, TUV Rheinland or Verbands der Elektrotechnik (VDE) shall be involved to judge the claim finally. All fees and expense associated with the test shall be borne by Suntech.

Suntech reserves the right to deliver an equivalent module at the same or higher power of a different type should the defective module model not be in production at the time of the claim. We do not consider this to be appropriate in terms of differences in power, because those parameters could be necessary in order to replace properly and successfully the defective modules.

10.2 Warranties and guarantees comparison

The table below shows a comparison of the warranties and power tolerances of several of the other currently available modules compared above.

Table 34: Comparison of several currently available PV modules Nameplate capacity Workmanship and Performance Guarantee (% of Manufacturer tolerance Materials Warranty power output) Suntech 0/+5% 10 years 1 year/97%, 0.7% degradation annually, 25 years/80.2% G1 0/+5W 10 years 1 year/97%, year 2 to 24/0.65% degradation annually, 25 years/81.4% G2 0/+5W 10 years 1 year/97%, year 2-24/0.7% degradation annually, 25

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Nameplate capacity Workmanship and Performance Guarantee (% of Manufacturer tolerance Materials Warranty power output) years/80% G3 0/+5W 10 years 10 years/91.2%, 25 years/80.7% G4 +/-3% 12 years 1 year/97%, 0.7% degradation annually, 25 years/82% G5 +/-3% 10 years 1 year/97.5%, 0.7% degradation annually, 25 years/ 80.7% G6 +/-3% 10 years 12.5 years/90%, 25 years 80% G7 +/-3% 10 years 1 year/97%, 0.7% degradation annually, 25 years/80.2% G8 +/-3% 10 years 12 years/90%, 25 years/80% G9 0/+5W 10 years 1 year/97%, 0.7% degradation annually, 10 years/ 90%, 25 years/80% G10 ±5W 12 years 5 years/95%, 12 years/90%, 18 years/85%, 25 years 80% G11 +/-3% 10 years 1 year/97%, 0.6% degradation annually, 10 years/92%, 25 years/83% G12 +/-2% 10 years 1 year/97%, 0.7% degradation from second year onwards G13 0/+4% 10 years 1 year/ 97%, 0.7% degradation annually, 25 years/80.2% G14 0/+3% 10 years 5 years/95%, 10 years/90%, 15years/87%, 20years/83%, 25 years/80% G15 +/-5% 5 years 10 year/90%, 25 year/80% G16 0/+5W 10 years 1 year/97.5%, linear degradation, 25 years/ 80%

We consider the linear peak performance warranty to be in line with current market standards. We also consider the positive nameplate capacity tolerance at the upper end of market standards.

Though the acquisition of Wuxi Suntech Power Co., Ltd. by Shunfeng Photovoltaic International Limited was finalised on the 7th of April 2014, Wuxi Suntech will continue to underwrite all the product and performance warranties for the products manufactured in the past and contracts entered no matter before or after the start of its restructuring phase on 20th March 2013. The continuity of warranties on products manufactured in the past was issued in a Customer Warranty Letter on Manufacturer’s home page on the 18th April 2014.

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10.3 Third party insurance

Suntech provided some informative material on third party insurance from SolarIf to cover damages on the overall PV plant. The insurance includes the option for Inherent Defect Warranty for covering further damages or defects on components, when manufacturer’s warranty is not applicable. The optional inherent defect cover can be taken out up to a maximum period of 20 years. The insurance can be taken out worldwide and Suntech is certified from the 4th May 2013 until the 12th December 2014. Suntech provided the detailed terms and conditions of the third party warranty, as well as references on the insurance broker and provider.

OST notes that the inherent defect cover only applies to PV-installations of at least 1 MWp. Based on the nature of the potential insurance arrangements, an insurance advisor should be engaged by a prospective purchaser to confirm arrangements are appropriate.

10.4 Product Liability Insurance

OST has sighted two product liability Insurance policies stipulated with:  Chubb Insurance (China) Company Limited on 10th March 2014  Yingda Taihe Property Insurance on 1st February 2014 (not applicable to Europe or the UK)

10.4.1 Chubb Insurance (China) Company Limited

OST has reviewed the Liability Insurance policy taken out with Chubb Insurance (China) Company Limited, effective from 10th March 2014 and valid until 10th March 2015.

The general liability insurance policy covers bodily injury (on persons or organisations) and property damage arising out of the solar modules sold worldwide. Damages will be paid by insurance in case the Manufacturer is legally obliged to pay.

The insurance coverage applies, provided that the occurrence of the damage is not before the 10th March 2014 and the claim is received within the expiry date of the agreement, although extensions are possible in a list of circumstances. The policy endorsement coverage applies worldwide.

A complex list of exclusions is reported for the policy that can be briefly summarized as follows:  Damages caused by aircraft products or arising from use of nuclear energy, pollutants, tobacco, etc.; damages arising from act of terrorism or wars;  Damages connected with use of asbestos or biological agents;  Loss that has to be paid in relation with liability to an existing contract or agreement.  Loss, cost and expenses due to employment related practices or Employer’s liability towards Employees.  Intellectual property laws and rights violation, enhancement, maintenance of any property.  Expected or intended damages.

The insurance policy has an aggregate premium limit of USD 10,000,000, which is progressively reduced once a claim is paid, and a limit of USD 10,000,000 for each claim occurrence.

Although the documentation on liability insurance was provided specifically for PV cells, modules and PV systems, which were all referred to as the ‘Product’, the wording of the document is not

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clear about the underperformance of the ‘Product. In particular, the policy excludes ‘Damage To Your Product’, where ‘Your Product’ is defined to mean goods or products manufactured by Suntech. ‘Your Product’ also includes representations or warranties made at any time with respect to the durability, fitness, performance, quality or use of ‘Your Product’. The policy defines terms of coverage and exclusions only in a general way and not specifically related with the Product’s application (e.g.: installation of modules on PV plants, roof-top or ground mounted, etc.).

10.4.2 Yingda Taihe Property Insurance

Suntech has also provided details of a product liability insurance stipulated with Yingda Taihe property insurance, with coverage in Japan. OST has not reviewed this product liability insurance as it is not applicable to Europe or the UK.

We recommend that the terms of the Product Liability Insurance policies are reviewed by an insurance advisor to confirm that the arrangements are appropriate.

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11 Environmental, Health and Safety Review

This section of the report discusses the findings of our desktop review of Suntech’s Environmental, Health and Safety (EHS) management system, against relevant international lender Environmental, Health and Safety (EHS) guidelines, namely International Finance Corporation (IFC), World Bank, and the Equator Principles.

In order to manage their investment risks appropriately, project financiers and lending institutions require their investments to comply with minimum environmental, social and health and safety standards, and increasingly are seeking to ensure that their funds are ethically used, without detrimentally impacting on the environment or society in which the project is located.

These standards are principally focussed on the potential impact and mitigation of environmental and social risks associated with the direct development of projects; however, the standards also require the responsible sourcing of materials and their supply chain. In general IFC and World Bank EHS standards and guidelines are used as a benchmark to gauge potential environmental and social risks, and therefore this review is based on compliance against these.

As presented below, the international standards emphasise the protection of workers and critical ecological habitats. However, we have also included a more general appraisal against other elements of these standards.

Suntech has provided OST Energy with the following EHS information:  Annual Reports to the Local Environment Authority (2013 and 2014) – Documents in Chinese  EIA for cell manufacturing Facilities – Documents in Chinese  2014 Training Plan  ISO 14001  Suntech Group Management Policy  OHSAS 18001 Audit Report  OHSAS 18001 Certificate  Statement from Wuxi Environment Protection Agency – Document in Chinese  Recruitment and Hiring procedure  Training Procedure – Document in Chinese  Worker Organisation List – Document in Chinese  Worker Comments and Complaints Management Procedure – Child and Young Labour Management Procedure

11.1 International Lender EHS Guidelines

Below is a summary of the principle international lender EHS guidelines that may be relevant for project financing, based on the following institutions:  IFC/World Bank  Equator Principles  European Bank for Reconstruction and Development (EBRD)

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11.1.1 IFC/World Bank

IFC, a member of the World Bank Group, is the largest global development institution focused exclusively on the private sector in developing countries.

The International Finance Corporation (IFC) is an international financial institution which offers investment, advisory, and asset management services to encourage private sector development in developing countries. The IFC is a member of the World Bank Group and is headquartered in Washington, D.C., United States. It was established in 1956 as the private sector arm of the World Bank Group to advance economic development by investing in strictly for-profit and commercial projects which reduce poverty and promote development.

The principal IFC guidelines and standards covering environmental, social, and health and safety relevant to Suntech’s business are as follows:  Policy on Environmental and Social Sustainability (1st Jan 2012): this defines IFC's commitments to environmental and social sustainability.  Performance Standards on Environmental and Social Sustainability (1st Jan 2012): this defines clients' responsibilities for managing their environmental and social risks.  Environmental, Health, and Safety (EHS) - General Guidelines (30th April 2007)  EHS Guidelines for Semiconductors & Other Electronics Manufacturing (30th April 2007)  Environmental and Social Review Procedures (15th April 2013); this sets out how IFC undertakes environmental and social reviews.

IFC Performance Standards identifies the required standards that IFC invested projects should achieve and is therefore the principal reference document. The Performance Standards consist of the following:  Performance Standard 1: Assessment and Management of Environmental and Social Risks and Impacts  Performance Standard 2: Labour and Working Conditions  Performance Standard 3: Resource Efficiency and Pollution Prevention  Performance Standard 4: Community Health, Safety, and Security  Performance Standard 5: Land Acquisition and Involuntary Resettlement  Performance Standard 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources  Performance Standard 7: Indigenous Peoples  Performance Standard 8: Cultural Heritage.

With regards to ‘supply chains’ Performance Standard 1 states the following:

“Where the client can reasonably exercise control, the risks and impacts identification process will also consider those risks and impacts associated with primary supply chains, as defined in Performance Standard 2 (paragraphs 27–29) and Performance Standard 6 (paragraph 30)”.

One of the objectives of Performance Standard 2 is to “protect workers, including vulnerable categories of workers such as children, migrant workers, workers engaged by third parties, and workers in the client’s supply chain”.

The scope of application of Performance Standard 2 applies to workers engaged by the client’s primary suppliers (supply chain workers), and specifically it requires the client to apply the following requirements:

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 Where there is a high risk of child labour or forced labour in the primary supply chain, the client will identify those risks consistent with paragraphs 21 and 22 above. If child labour or forced labour cases are identified, the client will take appropriate steps to remedy them. The client will monitor its primary supply chain on an on-going basis in order to identify any significant changes in its supply chain and if new risks or incidents of child and/or forced labour are identified, the client will take appropriate steps to remedy them.  Additionally, where there is a high risk of significant safety issues related to supply chain workers, the client will introduce procedures and mitigation measures to ensure that primary suppliers within the supply chain are taking steps to prevent or to correct life- threatening situations.  The ability of the client to fully address these risks will depend upon the client’s level of management control or influence over its primary suppliers. Where remedy is not possible, the client will shift the project’s primary supply chain over time to suppliers that can demonstrate that they are complying with this Performance Standard.

Performance Standard 6, also sets out the following requirements for Supply Chain:

“Where a client is purchasing primary production that is known to be produced in regions where there is a risk of significant conversion of natural and/ or critical habitats, systems and verification practices will be adopted as part of the client’s ESMS to evaluate its primary suppliers. The systems and verification practices will (i) identify where the supply is coming from and the habitat type of this area; (ii) provide for an on-going review of the client’s primary supply chains; (iii) limit procurement to those suppliers that can demonstrate that they are not contributing to significant conversion of natural and/or critical habitats (this may be demonstrated by delivery of certified product, or progress towards verification or certification under a credible scheme in certain commodities and/or locations); and (iv) where possible, require actions to shift the client’s primary supply chain over time to suppliers that can demonstrate that they are not significantly adversely impacting these areas.”

11.1.2 Equator Principles

The Equator Principles (EPs) is a credit risk management framework for determining, assessing and managing environmental and social risk in Project Finance transactions. The EPs are adopted by financial institutions and are applied where total project capital costs exceed US$10 million. The EPs are primarily intended to provide a minimum standard for due diligence to support responsible risk decision-making.

The EPs are based on the IFC / World Bank Performance Standards on social and environmental sustainability, as are presented above. The EPFI will only provide Project Finance and Project - Related Corporate Loans to Projects that meet the requirements of Principles 1 – 10, as follows:  Principle 1: Review and Categorisation  Principle 2: Environmental and Social Assessment  Principle 3: Applicable Environmental and Social Standards  Principle 4: Environmental and Social Management System and Equator Principles Action Plan  Principle 5: Stakeholder Engagement  Principle 6: Grievance Mechanism  Principle 7: Independent Review  Principle 8: Covenants  Principle 9: Independent Monitoring and Reporting

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 Principle 10: Reporting and Transparency.

11.1.3 EBRD E&S Standards and Guidelines

The European Bank for Reconstruction and Development (EBRD) is a multilateral development bank, using investment as a tool to help build market economies and democracies in 30 countries from central Europe to central Asia.

The EBRD adopted its first Environmental Policy back in 1991 and has been periodically updated. The latest update is the May 2008 Environmental and Social Policy, reaffirming EBRD’s commitment to ensure that the projects it finances are both socially and environmentally responsible. The Policy specifies a set of 10 performance requirements (PRs) to which projects are expected to meet in order to obtain financial support from the EBRD, as follows:  PR 1: Environmental and Social Appraisal and Management  PR 2: Labour and Working Conditions  PR 3: Pollution Prevention and Abatement  PR 4: Community Health, Safety and Security  PR 5: Land Acquisition, Involuntary Resettlement and Economic Displacement  PR 6: Biodiversity Conservation and Sustainable Natural Resource Management  PR 7: Indigenous Peoples  PR 8: Cultural Heritage  PR 9: Financial Intermediaries  PR 10: Information Disclosure and Stakeholder Engagement.

In addition to the above ten Performance Requirements (PRs) that set out the requirements and standards the EBRD requires of its clients and projects, EBRD has set an Environmental and Social Procedures (April 2010) which establishes the broad framework which governs how projects are appraised and monitored by the Bank. Within the Environmental and Social Procedures, EBRD requires supply chain issues to be considered when defining the scope of Environmental and Social Due Diligence.

11.2 Suntech’s EHS Management

We have undertaken a review of available information relating to the EHS management system against the above standards. The findings are presented under the following relevant IFC Performance Standards categories:  Assessment and Management of Environmental and Social Risks and Impacts  Labour and Working Conditions  Resource Efficiency and Pollution Prevention  Community Health, Safety, and Security  Biodiversity Conservation and Sustainable Management of Living Natural Resources.

IFC Performance Standards associated with Land Acquisition and Involuntary Resettlement, Indigenous Peoples, and Cultural Heritage are not considered relevant to this review.

Below is a summary of our findings based on the information provided by Suntech relevant to EHS management.

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11.2.1 Assessment and Management of Environmental and Social Risks and Impacts

Suntech has implemented an Environmental, Health & Safety (EHS) Management System. The environmental component of which is based on the ISO 14001 – Environmental Management System (EMS) standard. The Wuxi City manufacturing facility has been certified as compliant with ISO 14001 by SGS System Certification on 28th August 2013 (certificate valid until 5th August 2015). Overall, the implementation of an ISO 14001 certified EMS demonstrates adequate management of environmental risks.

External ISO 14001 audits are undertaken annually. OST has been provided with External Audit reports to verify the requirements of ISO 14004 from 2013, which recommended certification and identified no non-conformities, either minor or major at the facility.

Overall, the implementation of an ISO 14001 certified, formal EMS demonstrates adequate management of environmental risks and meets the IFC Performance Standard 1.

11.2.2 Labour and Working Conditions

Relevant aspects of IFC Performance Standard include:  Child Labour – no employment of children and the identification of all persons under the age of 18. Children under the age of 18 will not be employed in hazardous work.  Forced labour - no forced labour to be employed  Occupational Health and Safety - provide a safe and healthy work environment.  Non-Discrimination and Equal Opportunity - employment to be based on the principle of equal opportunity and fair treatment, and not discriminating.  Grievance mechanism - provide a grievance mechanism for workers to raise workplace concerns.  Worker accommodation - where worker accommodation services are provided ensure the provision of basic services. Workers’ accommodation arrangements should not restrict workers’ freedom of movement or of association.

Of the above the key issue identified with supply chains relates to child and forced labour, and worker safety.

Suntech has provided OST with documents relating to its Labour Contract and we have been informed by Suntech that they currently employ no workers under the age of 18. However, whilst Suntech’s employment policy stipulates that the company will work with interns and students between the ages of 16 and 18, the document does not state a specific age below which a person may not be employed, or is regarded as a ‘child’. OST recommends that this is clearly stated.

With regards to non-discrimination, Chinese Labour laws and government policies include provisions to promote equal opportunity in employment. Suntech’s Recruitment Policy states that ‘Discrimination against race, ethnic groups, gender, age, nationality, religion and physiology is forbidden.’ OST is also aware that Suntech’s Wuxi facility’s employees are entitled to become members of various worker organisations, the names of these have been provided in Chinese with no further detail on what support or benefits these organisations offer.

Suntech’s Wuxi facility does not provide any worker accommodation. The IFC’s requirements with regards to ‘the quality and management of the accommodation and provision of basic

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services, under the criteria of ‘Working Conditions and Management of Worker Relationship’ is not considered for this manufacturer.

OST has not received any documents relating to Suntech’s formal H&S Policy or Management System. However, the Suntech Wuxi Facility has been certified as compliant with ISO 18001 standards on 3rd September 2013 (valid until 1st September 2016), demonstrating a management policy that ensures all employees create and maintain a safe and clean environment

Suntech’s has stated that there have been no accidents or incidents at the facility in the past 3 years; OST requests proof in this regard.

We have been provided with a detailed schedule of safety training for workers, as part of the EHS Management system. OST has also been provided with Suntech’s Training procedure, however, this document has been provided in Chinese, as such OST is unable to review the depth and scope of the training provided to employees. The training programmes effectiveness is evaluated on an annual basis.

Overall, OST considers that, in general, the Suntech Wuxi facility meets with the IFC Performance Standard 2, with relevance to supply chain. However, we recommend provision of the incidents and accidents records from the past three years.

11.2.3 Resource Efficiency and Pollution Prevention

The EHS Guidelines (for both General and for Semiconductors & Other Electronics Manufacturing) covers the following environmental aspects:  Air Emissions and Ambient Air Quality  Energy Conservation  Wastewater and Ambient Water Quality  Water Conservation  Hazardous Materials Management  Waste Management  Noise  Contaminated Land.

We have received a copy of the EIA for cell manufacturing facilities, and the Annual Environmental Reports to the local Environmental Authority from the Suntech Wuxi facility for 2014. However, these documents have all been provided in Chinese, therefore OST is unable to fully review the information. OST has, however, been informed that all reports state that the factory meets all government requirements and therefore are in line the IFC Standards with regards to air emissions, wastewater discharges and waste gas levels. OST has also been informed that there have been no fines or notifications raised against Suntech’s Wuxi facility from the Government or Local Authority.

Suntech has confirmed that they comply with environmental laws and legislation, and have provided a Certificate of Compliance from the relevant local Environmental Protection Authority for their Wuxi facility in Chinese, which cannot be fully reviewed, however we have been informed that it confirms that they comply with environmental laws and legislation and that there are no environmental or administrative penalties for the site.

IFC Environmental and Social Sustainability Performance Standard 3 also includes requirements for the implementation of technically and financially feasible and cost effective measures for

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improving efficiency in its consumption of energy, water, as well as other resources and material inputs, with a focus on areas that are considered core business activities.

OST has not received any specific details of efficiency measures that have been implemented at the Suntech Wuxi facilities, or the quantifiable results this has had in terms of resource efficiency.

Overall we consider that in general the Suntech Wuxi facility meets the requirements of IFC Performance Standard 3 as relevant for a primary supply chain. However, we request evidence of having on-going compliance with the relevant Environmental Protection Authority in English, in addition to providing all relevant documentation with regard to resource efficiencies which have been implemented on-site.

11.2.4 Community Health, Safety, and Security

The implementation of Suntech’s EHS management system, discussed above, would include the health, safety and security of the local community. However, it is acknowledged that incidents can still occur that have the potential to impact the local community.

Suntech has not provided any information demonstrating their support and involvement in community based (CSR) projects through the provision of outreach programmes, public welfare and voluntary activities.

Overall we consider that Suntech meets the requirements IFC Performance Standard 4 as relevant for a primary supply chain. However OST recommends that the Wuxi facility investigates how they can further involve the local community with specific regard to the promotion and use of Solar PV, community development and education. We advise demonstrating this standard via the implementation of a formal CSR policy, which will measure quantifiable benefits to the local community.

11.2.5 Biodiversity Conservation and Sustainable Management of Living Natural Resources

We consider that Suntech meets the requirement set out in IFC Performance Standard 6 with respect to supply chain, since this aspect focusses on agricultural activities and/or the consumption of natural resources, such as animal husbandry, wood and natural fibres etc.

11.3 Conclusion

Following our review of information provided, we consider that the Suntech Wuxi production facilities are, in general, in-line with international lender requirements, based on IFC and World Bank standards, for a primary supply chain.

We recommend that Suntech provides English versions of all requested documentation in order for a full review to be carried out. We do not require a full translation of the EIA, whowever, if an English version of the EIA non-technical summary (NTS) is available please provide. We also recommend that information and company policy regarding continuing efficiency measures is provided in order to further demonstrate Suntech’s compliance with IFC Performance Standard 3.

OST also recommends that Suntech implements and demonstrates a robust CSR policy at their Wuxi facility which will measure quantifiable benefits to the local community, with specific focus on the promotion and use of Solar PV, community development and education.

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