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In January 2021 Ethical Consumer viewed received a questionnaire response from AES Solar with supporting documents.

Supply chain policy (poor)
A strong policy would include the following commitments: no use of forced labour, permission of freedom of association, payment of a living wage, the restriction of working hours to 48 hours plus 12 overtime (without exception), no use of a child labour (under 15 or 14 if ILO exempt), no discrimination by race, sex or for any other reason.
In its questionnaire response of January 2021 AES stated:
All employees in the supply chain are required to avoid any activity that might lead to, or suggest, a breach of the AES Solar Suppliers and Subcontractors procedure along with the Bribery Statement and Anti-Slavery and Human Trafficking Policy.
The latter covered forced labour as part of its Modern Slavery policy. The company stated it was a Living Wage employer but there was no indication that that applied to its whole supply chain.

"We manufacture and assemble the majority of our products from our headquarters in Forres. With the majority of our materials from the local, domestic, and European market, the environmental impact of the transportation is minimal. AES Solar is actively resisting the less sustainable trend of sourcing materials from Asia in order to reduce our carbon footprint and support producers closer to home.

Therefore the company was considered to have an effective if not explicity supply chain policy

Stakeholder engagement (rudimentary)
Ethical Consumer deemed it necessary for companies to demonstrate stakeholder engagement, such as through membership of the Ethical Trade Initiative, Fair Labour Association or Social Accountability International.
Companies were also expected to engage with Trade Unions, NGOs and/or not-for-profit organisations which could systematically verify the company's supply chain audits,
and for workers to have access to an anonymous complaints system, free of charge and in their own language.
In its questionnaire response of January 2021 AES stated:
"The prevention, detection, and reporting of any issues in any part of our business or supply chains is the responsibility of all those working for us or under our control. We aim to encourage openness and will support anyone who raises genuine concerns. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith any suspicions. Complaints may be received verbally, either through personal contact or by telephone, or in writing, either by letter or e-mail."
Because it had a complaints system the company was considered to have a rudimentary approach to stakeholder engagement.

Auditing and Reporting (rudimentary)
Ethical Consumer deemed it necessary for companies to have an auditing and reporting system. Results of audits should be publicly reported and quantitatively analysed. The company should have a scheduled and transparent audit plan that applies to their whole supply chain, including some second tier suppliers. The company should also have a staged policy for non-compliance. The costs of the audit should be borne by the company.
In its questionnaire response of January 2021 AES stated:
"The performance of all current suppliers is re-evaluated at least annually at Internal Review. Where performance is deemed unsatisfactory the supplier may be informed for action, (specific issues and nonconformities found; observations and recommendations for improvement), and if necessary, removed from our Approved Suppliers and Subcontractors List."
The reporting of these audits was not public, they were 'internal reviews'. It was unclear whether the audits applied to second tier suppliers. Therefore the company was considered to have a rudimentary approach to auditing and reporting.

Difficult issues (rudimentary)
Ethical Consumer also deemed it necessary for companies to address other difficult issues in their supply chains. This would include ongoing training for agents, or rewards for suppliers, or preference for long term suppliers. It would also include acknowledgement of audit fraud and unannounced audits, and measures taken to address the issue of living wages, particularly among outworkers, and illegal freedom of association.

There was a brief statement on the living wage on its CSR webpage. It stated "AES Solar welcomed the Living Wage increase and is proud to be an accredited Living Wage employer – rewarding a day’s work with pay that reflects real-world living costs. The benefits of a fairly-paid, motivated and skilled workforce are clear every day." Though this did not extend to the company's supply chain, as the company conducted its own manufacturing, this commitment was assumed to cover the company's own manufacturing workers.
Therefore the company was considered to have a rudimentary approach to difficult issues.

In January 2021 Ethical Consumer viewed the Kensa Group website for information on how the company managed workers' rights in its supply chain. No explicit supply chain policy could be found. However, the company only manufactured its products (heatpumps) in the UK, which is considered to have reasonable labour standards. While gross exploitation of labour has been found in the UK, such as in the fast fashion sector, this was not considered to be an area at high risk of such labour exploitation.

As AES only manufactured in the UK and was a small company with a turnover of less than £10.2m it was eligible for an exemption and therefore received Ethical Consumer's best rating for Supply Chain Management.


Questionnaire response Jan 2021 (25 January 2021)

In January 2021 Ethical Consumer viewed AES Solar's website for the company's conflict minerals policy. No policy was found. AES manufactured solar thermal systems, including digital controllers.

Conflict minerals are minerals mined in conditions of armed conflict and human rights abuses, notably in the eastern provinces of the Democratic Republic of Congo (DRC). The minerals in question are Tantalum, Tin, Tungsten and Gold (3TG for short) and are key components of electronic devices, from mobile phones to televisions.

Ethical Consumer expected all companies manufacturing electronics to have a policy on the sourcing of conflict minerals. Such a policy would articulate the company's commitment to conflict-free sourcing of 3TG minerals and a commitment to continue ensuring due diligence on the issue. The policy should also state that it intended to continue sourcing from the DRC region in order to avoid an embargo and that the company had membership of, or gave financial support to, organisations developing the conflict-free industry in the region.

Their questionnaire response to a question about conflict minerals policy stated:
"AES Solar aim to source all materials from ethical and socially responsible sources. We obtain evidence to ensure as far as possible (within reason based on our size and resources) that the supply chain of our components, from raw material through to assembly, meets these requirements.
AES Solar undertake reasonable measures such as enquiries and obtaining written commitments or certifications to be confident our suppliers operate responsibly with respect to conflict materials. The majority of our materials and components are sourced within the UK and the remainder within the EU from reputable companies with no direct connection to conflict materials that we can be aware of.
Our main supplier of extruded metal products (Hydro) provides a written commitment to ensure the same, with respect to the sourcing of their raw materials and components. These extruded metal products make up the highest proportion of our component materials.
AES Solar commit to only using materials from smelters/remelters that are conflict free. Our supplier of components derived from such sources confirm they have measures in place to ensure the same."

Hydro stated:
"Hydro take very seriously concerns that profits from conflict minerals (i.e., certain minerals, including tin, tantalum, tungsten and gold) may be fueling human rights violations, labour abuses and environmental degradation and are committed to ethical sourcing of any minerals used in our products. Following a good faith diligent inquiry, we do not have any reason to believe that our manufacturing facilities use any “conflict minerals”."

Due to the fact the company did not have a robust policy for ensuring that its suppliers only used verfiried conflict free smelters or support of any conflict free iniatives it received Ethical Consumer's worst rating for its policy on conflict free minerals and lost a whole mark under the Habitats and Resources and Human Rights categories.


Questionnaire response Jan 2021 (25 January 2021)