Frequently Asked Questions
We Are Respectful and Equitable
We are Trustworthy and Fair
CSI employees must never ask for Business Courtesies that benefit them personally, regardless of value
For approval of this, you must seek approval by completing the form set out in Schedule C that shall be submitted for approval to Employee’s Supervisor and sent to Compliance Department for approval and retention, IF:
the value of the gift exceeds $25 USD
the value of the meal or entertainment exceeds $50 USD;
Travel and Lodging is involved;
Acceptance of Travel and Lodging for any amount and Business Courtesies exceeding the threshold of 250 USD must be also authorized by Chief Compliance Officer or his or her designee.
In case of lack of authorization, the Business Courtesy must be refused or returned. If an Employee is unable to refuse or return a gift for any reason (e.g. because it would be inappropriate to do so), the Employee must report the gift to the Employee’s supervisor, who will advise the Compliance Officer of receipt of the gift. The Compliance Officer will establish rules for dealing with such gifts, including requiring the Employee to donate the gift to an appropriate community organization.

This should be disclosed to the compliance manager. The important thing to consider in this situation is whether there is an open opportunity or tender for this prospective business partner and/or vendor, and how much the meal costs. Because you believe it is expensive, and it’s a prospective partner, disclosing this is the best way to ensure it doesn’t appear that the partner only got the business because it offered benefits to our employees. This is particularly important if you are the decision maker on whether that partner gets the business.

Please refer to our <<<Travel Policy>>> for the answer to these questions. It specifies all reimbursement thresholds and reasonable travel expenses. The Travel Policy is managed by our Finance Department.

You should disclose this information to the compliance manager. Does this mean that there is a conflict? Not necessarily.
Whether it is an actual conflict depends on your position and whether the position has any agency or autonomy over the Canadian Solar EMEA MSS relationship. You should also have your spouse/partner disclosure this fact to their employer.

There is no need to report this per se, but more importantly, what you should make sure not to do is interfere with the hiring process or advocate for that new-hire because you want to secure the CEO's business. Giving the CEO's son a job because you believe it would secure his business is not acceptable and could be illegal.

We Are Protective and Discretionary
Usually, insider trading rules apply to individuals who have access to material non-public information about companies with publicly listed securities, to which you may be privy at Canadian Solar EMEA MSS. However, insider trading rules can apply to private companies when purchasing stock from employees and other shareholders, as they do in the public company setting.

No. All software, source code, and documentation generated or provided by teammates, consultants, or contractors for Canadian Solar EMEA MSS belongs to Canadian Solar EMEA MSS. Canadian Solar EMEA MSS's code, data, and other property must remain with Canadian Solar EMEA MSS. An “asset” is a computer, storage account, or other device or application belonging to Canadian Solar EMEA MSS, which means teammates must not store Canadian Solar EMEA MSS code, or data, on a home computer or personal storage account.

If you are an employee, customer, job applicant, or marketing recipient of Canadian Solar EMEA MSS, you can fill out a data subject access request (DSARs) <<<here>>>, and we will provide you with that information.

The Company places a high value on its credibility and reputation in the community. What is written or said about the Company in the news media and investment community directly impacts our reputation, positively or negatively. Our policy is to provide timely, accurate and complete information in response to public requests (eg, media and analysts), consistent with our obligations to maintain the confidentiality of competitive and proprietary information and to prevent selective disclosure of market-sensitive financial data. To ensure compliance with this policy, all news media or other public requests for information regarding the Company should be directed to the Company’s Investor Relations Department. The Investor Relations Department will work with you and the appropriate personnel to evaluate and coordinate a response to the request.

Yes, for work purposes.

You should immediately report this security incident to our Security Team. Contact Torsten Dobroschke or Ken Land immediately. Reporting this can help protect Canadian Solar EMEA MSS against a possible cyber-attack.

You should immediately report this security incident to our Security Team. Contact Torsten Dobroschke or Ken Land immediately. Reporting this can help protect Canadian Solar EMEA MSS against a possible cyber-attack.

Please report this to the IT department by flagging the email as Phishing via Outlook. To do so, click “Message” in the top menu, “Report Junk” and select Phishing.

You should immediately report this security incident to our Security Team. Contact Torsten Dobroschke or Ken Land immediately. Reporting this can help protect Canadian Solar EMEA MSS against a possible cyber-attack.

We Are Collaborative and Compliant
You should partner with the Ethics & Compliance Office to investigate this conduct. You can report your concern directly to the Office or via the Speak-Up Helpline.

Yes, when onboarding any client regardless of whether you have worked with them before, we need to understand who they are as a company, their owners, our business justification for hiring them and make sure they conduct business ethically and legally. So when you are thinking about starting a new project with a vendor, this is the perfect time to partner with the Ethics & Compliance Office to ensure the proper checks on that 3rd party have been performed.

Working with your spouse’s company could create a potential conflict of interest, and you should disclose that to the Ethics & Compliance Office MSS EMEA. Please visit our Conflicts of Interest page for more information.

Leave the event and make sure you document the situation to the Ethics & Compliance Office via the Speak-Up Helpline. Talking about price, territories, or strategic alliances with competitors is illegal and could get Canadian Solar EMEA MSS into a lot of trouble.

We Are Sustainable and Charitable
Visit our <<<insert link here>>> to learn more about our ESG efforts.

This may represent a conflict of interest, Why? whether your job side creates a conflict of interest depends on the type of the company you are working for, the number of hours you spend doing the work, and the resources you are using to do the work. Disclosing any second job, or side job, is your best move so Canadian Solar EMEA MSS is aware, and the potential conflict can be managed, you can disclose such information to your supervisor, HR, Compliance Manager.

Canadian Solar EMEA MSS support certain non-profit organizations as part of the global Social Responsibility Program. There are certain rules that shall be followed in case you want to commit with a new social program or donation: a) In case you have a close relationship with the proposed recipient, you should disclose that relationship to your Supervisor, HR, Compliance b) Any employee shall seek prior approval from Department Head, Country General Manager Manager, Local Legal and Chief Compliance Officer or his nominee before any donation is signed on behalf of the Company.

This is possible but would be considered a charitable contribution, so you should get it approved by Ethics & Compliance so that they understand and can evaluate how Canadian Solar EMEA MSS's resources will be used and leveraged.

How to Report a Concern
Your organization provides a list of incident types that it recommends you choose for your report, and you always have the option of typing in your own incident type.

Any employee, member, contractor, or third party who finds themselves in a situation that may raise legal or ethical issues or that is identified in the code of conduct, may report concerns.

It is your preference and makes no difference whether you make your report through the website or by phone. The call center agents will follow the same steps for filing a report that you would go through on the website, and either way, your concern will be received confidentially, anonymously (if you choose), and routed to only specific individuals within the organization and our outside legal counsel who are responsible for evaluating the information you provided.

What to Expect in the Reporting Process
If you witness or experience issues in the following areas, please reach out.
- Public procurement
- Financial services, products, and markets
- Product safety and compliance
- Transport safety
- Protection of the environment
- Radiation protection and nuclear safety
- Food and feed safety, animal health and welfare
- Public health
- Consumer protection
- Protection of privacy and personal data
It also applies to breaches relating to Union competition rules, breaches harming the EU's financial interests and, in view of their negative impact on the proper functioning of the internal market, to breaches of corporate tax rules or arrangements whose purpose is to obtain a tax advantage that defeats the object or purpose of the applicable corporate tax law.

- Your concern is taken seriously.
- You are treated with dignity and respect.
- You are not required to identify yourself.
- Your communication is confidential.
- Your incident report will be received by Convercent and sent to the individuals deemed appropriate within your organization.
- Your organization handles all incident reports according to its internal investigatory procedures.
- Your concern is addressed, and you are kept informed during the investigation.
- You are contacted when the investigation is complete and informed whether the findings are substantiated or unsubstantiated.
- You will not be retaliated against for good faith reporting.

Convercent is an organization dedicated to building best in class ethics and compliance solutions. It allows employees to share concerns or incidents, while easily maintaining anonymity, fostering an atmosphere where every voice is heard.

Your incident report is NOT automatically sent to law enforcement. Only if your organization feels law enforcement should receive a copy, or if the law requires it, will your incident report be submitted to the police.

In all instances, every effort will be made to ensure that information relating to a reported incident is kept confidential and communicated on a need-to-know basis only. Below are the different levels of anonymity you may select:
- Remain completely anonymous: You will not reveal your name or contact information. Your identity is completely protected on the incident report.
- Remain anonymous toward your organization: You are comfortable revealing your name and contact information to Convercent, but not to your organization. Convercent may contact you confidentially to gather additional information about the report yet will not reveal your identity at any time to your organization.
- Share my name and information: You do not care about anonymity. You choose to reveal your name and identity to both your organization and to Convercent.

All reports submitted are routed to only specific individuals within your organization and outside legal counsel who are responsible for reviewing and evaluating the specific category of information that you provided. Each of these recipients has vast experience in reviewing matters and conducting investigations in a thorough, impartial, and confidential manner.

Retaliation against anyone for reporting or participating in the investigation of any complaint is prohibited. Anyone found to have engaged in retaliation is subject to disciplinary action. If at any time you believe you have been subject to retaliation for raising a concern or for participating in the investigation of a concern raised, please immediately report it, so it can be properly investigated.

Following Up on a Concern
You'll be able to create a personal password, which you can use to check the status and updates of the report after it's been submitted. You won't be able to change anything, but you will be able to add additional details using the private case message board that is automatically created with a report.
