Tigo Anti-Human Trafficking Policy 

Policy Statement:

Tigo Energy, Inc. (“Tigo”) and the United States Government prohibit trafficking in persons. The U.S. Government’s policy prohibiting trafficking in persons is available at 48 CFR § 52.222-50 and is summarized below under the heading: “Summary of U.S. Government Policy of Prohibiting Trafficking in Persons.”

Tigo is committed to a work environment that is free from human trafficking and slavery, which for purposes of this policy includes forced labor and unlawful child labor. Tigo will not tolerate or condone human trafficking or slavery in any part of our global organization.

Tigo, as well as its employees, subsidiaries, contractors, subcontractors, vendors, suppliers, partners, and others through whom Tigo conducts business, are prohibited from participating in or being complicit with  any practice that constitutes trafficking in persons or slavery.

Tigo does not and will not permit its employees, subcontractors, vendors, suppliers, or other entities doing business with Tigo to engage in any form of human trafficking, including but not limited to those listed below. Tigo reserves the right to audit any and all contractors and subcontractors to determine compliance with this policy.  In addition, Tigo reserves the right to conduct any and all necessary investigations to ensure compliance with this policy, including investigations of its employees, subsidiaries, and contracting parties.  

Scope

This policy applies to all personnel employed by or engaged to provide services to Tigo, including, but not limited to, employees, officers, independent contractors and temporary employees of Tigo and Tigo’s subsidiaries (for ease of reference throughout this policy, “Employees”).

Every Employee is responsible for reading, understanding, and complying with this policy. Tigo’s managers are responsible for ensuring that Employees who report to them, directly or indirectly, comply with this policy and complete any certification or training required of them. If you have any questions or concerns relating to this policy, consult Tigo’s legal or human resources department.

Procedures

Report any conduct that you believe to be a violation of this policy to Tigo’s legal or human resources department. Reports may also be made by phone to +1 (408)402-0802, ext. 7200 or via the internet at the following website: www.tigoenergy.com, which allows anonymous reporting as permitted by applicable law.

If you are a victim of, have witnessed, or suspect any Human Trafficking you should contact law enforcement immediately or contact the National Human Trafficking Hotline via the below information.

National Human Trafficking Hotline

• Tollfree: 1 (888) 373-7888

• SMS: 233733 (Text "HELP" or "INFO")

• Website: humantraffickinghotline.org

Employees who fail to report actual or suspected misconduct may be deemed in violation of this policy.

Disciplinary Actions

Tigo will not tolerate retaliation against an Employee for reporting a concern in good faith or for cooperating with a compliance investigation.

Any violation of this policy may be grounds for disciplinary action, up to and including termination. Tigo and its subsidiaries have the exclusive right to interpret this policy regarding their respective Employees.

Violation of the U.S. Government’s policy against human trafficking may also result in criminal prosecution of responsible individuals.

Summary of U.S. Government Policy of Prohibiting Trafficking in Persons

U.S. Government policy prohibits trafficking in persons and slavery. Government contractors and their employees, subcontractors, subcontractor employees, and agents must not engage in any practice that constitutes trafficking in persons or slavery. This includes, but is not limited to, the following activities:

• Engaging in any form of trafficking in persons.

• Procuring commercial sex acts.

• Using forced labor in the performance of any work.

• Destroying, concealing, confiscating, or otherwise denying access by an employee to the employee’s identity or immigration documents, such as passports or drivers’ licenses, regardless of issuing authority.

• Using misleading or fraudulent practices during the recruitment of employees or offering of employment/contract positions, such as failing to disclose, in a format and language understood by the employee or applicant, basic information; or making material misrepresentations during the recruitment of employees regarding the key terms and conditions of employment, including wages and fringe benefits, the location of work, the living conditions, housing, and associated costs (if provided by the employer or agent), any significant cost to be charged to the employee or applicant, and, if applicable, the hazardous nature of the work.

• Using recruiters that do not comply with local labor laws of the country in which the recruiting takes place.

• Charging applicants recruitment fees.

• If required by law or contract, failing to provide return transportation, or failing to pay for the cost of return transportation upon the end of employment.

• If required by law or contract, failing to provide or arrange housing that meets the host country housing and safety standards.

• If required by law or contract, failing to provide an employment contract, recruitment agreement, or other required work document in writing with legally required information and in a language the employee understands.