IN BROAD DAYLIGHT Uyghur Forced Labour and Global Solar Supply Chains LAURA T. MURPHY & NYROLA ELIMÄ © 2021 Laura T. Murphy and Nyrola Elimä Citation: Murphy, L. and Elimä, N. (2021). “In Broad Daylight: Uyghur Forced Labour and Global Solar Supply Chains.” Sheffield, UK: Sheffield Hallam University Helena Kennedy Centre for International Justice. Acknowledgements: The authors would like to express gratitude to the many people who have contributed their knowledge and time to the development of this report and to research on forced labour in China – Jessica Batke, Penelope Kyritsis, Scott Nova, Jewher Ilham, Kate Larsen, Shannon Stewart, Chloe Cranston, Louisa Greve, Nury Turkel, Shawn Bhimani, Liz Carter, Rian Thum, Darren Byler, Timothy Grose, Nathan Ruser, Edmund Burke, Au- drey Masso, Rikard Elimä, and our student research team. We are grateful for all of the experts who contributed to our rapid review process as well as all of those who gave feedback on this report or provided research support who prefer to remain anonymous. We appreciate the input of our Chinese-language factchecker and our review- ers in the fields of Xinjiang studies, polysilicon/solar research, supply chain analysis, human rights due diligence, and labour rights. Our special thanks go to members of the Coalition to End Forced Labour in the Uyghur Region for their insights. About the authors: Laura T. Murphy is Professor of Human Rights and Contemporary Slavery at the Helena Ken- nedy Centre for International Justice at Sheffield Hallam University. She is author of the forthcoming Freedom- ville: The Story of a 21st Century Slave Revolt (Columbia Global Reports) and The New Slave Narrative: The Battle over Representations of Contemporary Slavery (Columbia University Press, 2019) as well as academic articles on forced labour. She has consulted for the World Health Organization, the U.S. Department of Health and Human Services, and the U.S. Office of Victims of Crime. She has provided expert evidence briefs regarding the situation in the Uyghur Region for the U.K. and Australian governments. She spent significant time in the Uyghur region between 2004 and 2009. Nyrola Elimä is a supply chain analyst who regularly collaborates with the Helena Kennedy Centre’s Forced La- bour Lab at Sheffield Hallam University. As a consultant, she provides research on Chinese corporate structures, supply chain mapping, and ESG risk assessment to scholars, investment firms, and international media organi- zations. She studied Retail Management at Lund University, and her research is informed by having lived and studied in the Uyghur Region for 19 years and by working as a customs broker and in import/export in Shanghai, Beijing, and other inland cities. She conducts research in Chinese, Uyghur, English, and Swedish, and is a Py- thon/R data analyst. Design and Layout: Southpaw Creative. Cover image credits: Kokodala News. Disclaimer: this publication is designed to provide accurate and authoritative information in relation to the sub- ject matter covered. It is provided with the understanding that the author and publisher are not engaged in rendering any form of professional or other advice or services through the publication of this report. The report reflects the authors’ own conclusions, based on inferences drawn from an analysis of publicly available sources. The aim of the report is to determine any potential exposures the named companies may have to the compulsory labour programmes instituted by the PRC government in the Xinjiang Uyghur Autonomous Region. No person or entity should rely on the contents of this publication without first obtaining professional advice. IN BROAD DAYLIGHT: UYGHUR FORCED LABOUR AND GLOBAL SOLAR SUPPLY CHAINS 2 MAY 2021 IN BROAD DAYLIGHT Uyghur Forced Labour and Global Solar Supply Chains LAURA T. MURPHY & NYROLA ELIMÄ THE HELENA KENNEDY CENTRE FOR INTERNATIONAL JUSTICE AT SHEFFIELD HALLAM UNIVERSITY is a leading centre for social justice and human rights research, practice, and pedagogy. It provides a vibrant environment at the cutting edge of legal and criminal justice practice which prepares students for excellence in their cho- sen professional careers. The centre is home to a range of social justice and human rights activities that include research, global engagement, impact on policy, professional training, and advocacy. Its central values are those of widening access to jus- tice and education, the promotion of human rights, ethics in legal practice, equality and a respect for hu- man dignity in overcoming social injustice. The centre works on high-profile projects in a vari- ety of human rights and social justice areas. Research and projects concern modern slavery, gender-based violence, hate crime, and many more. IN BROAD DAYLIGHT: UYGHUR FORCED LABOUR AND GLOBAL SOLAR SUPPLY CHAINS 4 CONTENTS EXECUTIVE SUMMARY 7 I. INTRODUCTION 9 Forced Labour in the Uyghur Region 9 Incentivizing Solar in the Uyghur Region 15 The Competitive Advantage of Forced Labour 17 The Purpose of This Report 18 2. RAW MATERIALS 20 Xinjiang Hoshine 20 Other Raw Materials Suppliers 25 Implications 27 3. POLYSILICON 28 Daqo New Energy Corp 28 GCL-Poly Energy Holdings Company 30 TBEA Co. & Xinte Energy Co 31 East Hope Group 33 Non-Xinjiang-Based Polysilicon Suppliers 34 Implications 35 IN BROAD DAYLIGHT: UYGHUR FORCED LABOUR AND GLOBAL SOLAR SUPPLY CHAINS 5 4. INGOTS, WAFERS, CELLS & MODULES 37 JinkoSolar Holdings Company 38 LONGi Green Energy Technology Company 40 Trina Solar Energy Company 41 JA Solar Holdings Company 42 Other Potentially Exposed Module Manufacturers Operating in the PRC 42 Implications 43 5. CONCLUSIONS & FUTURES 44 Expansion of Chinese Production Beyond Xinjiang 46 Global Alternatives 46 APPENDIX A: FORCED LABOUR EXPOSURES 48 Raw Materials 48 Polysilicon 49 Ingots Wafers, Cells & Modules 49 ENDNOTES 52 IN BROAD DAYLIGHT: UYGHUR FORCED LABOUR AND GLOBAL SOLAR SUPPLY CHAINS 6 EXECUTIVE SUMMARY The People’s Republic of China (PRC) has placed mil- • Hoshine Silicon Industry, the metallurgical-grade lions of indigenous Uyghur and Kazakh citizens from silicon producer in the region with the highest the Xinjiang Uyghur Autonomous Region (XUAR production capacity, has participated in labour or Uyghur Region) into what the government calls transfer programmes and has significant expo- “surplus labour” (富余劳动力) and “labour transfer” sure to forced labour through its quartz supplier. (劳动力转移) programmes. An official PRC govern- • All four of XUAR’s polysilicon manufacturers ment report published in November 2020 documents – Daqo, TBEA (and subsidiary Xinte), Xinjiang the “placement” of 2.6 million minoritised citizens in GCL, and East Hope – have reported their par- jobs in farms and factories within the Uyghur Region ticipation in labour transfer or labour placement and across the country through these state-sponsored programmes and/or are supplied by raw materi- “surplus labour” and “labour transfer” initiatives. The als companies that have. government claims that these programmes are in ac- • Daqo alone is a supplier to the four largest solar cordance with PRC law and that workers are engaged module manufacturers in the world – JinkoSolar, voluntarily, in a concerted government-supported Trina Solar, LONGi Green Energy, and JA Solar. effort to alleviate poverty. However, significant evi- • In 2020, China produced an additional 30% of dence – largely drawn from government and corporate the world’s polysilicon on top of that produced sources – reveals that labour transfers are deployed in in the Uyghur Region, a significant proportion the Uyghur Region within an environment of unprece- of which may be affected by forced labour in the dented coercion, undergirded by the constant threat of Uyghur Region as well. re-education and internment. Many indigenous work- ers are unable to refuse or walk away from these jobs, In the course of this research, we identified and thus the programmes are tantamount to forcible transfer of populations and enslavement. • 11 companies engaged in forced labour transfers • 4 additional companies located within industrial It is critical that we examine the particular goods that parks that have accepted labour transfers are being produced as a result of this forced labour re- • 90 Chinese and international companies whose gime. This paper focuses on just one of those indus- supply chains are affected tries – the solar energy industry – and reveals the ways forced labour in the Uyghur Region can pervade an This report seeks to increase the knowledge base upon entire supply chain and reach deep into international which the solar industry determines its exposures to markets. We concluded that the solar industry is par- forced labour in the Uyghur Region. We investigated ticularly vulnerable to forced labour in the Uyghur Re- the entire solar module supply chain from quartz to gion because: panel to better understand the extent to which forced labour in the Uyghur region affects international val- • 95% of solar modules rely on one primary ue chains. The examples of engagement in these pro- material – solar-grade polysilicon. grams are meant to provide stakeholders with the ev- • Polysilicon manufacturers in the Uyghur Region idence base upon which to judge risk of exposure to account for approximately 45% of the world’s forced labour in the solar supply chain. solar-grade polysilicon supply. IN BROAD DAYLIGHT: UYGHUR FORCED LABOUR AND GLOBAL SOLAR SUPPLY CHAINS 7 While Xinjiang accounts for 45% of the world’s so- 2020 Polysilicon