Good Governance & Business Excellence

In 2024, we introduced ESG Guidelines for our engineering, procurement, and construction (EPC) suppliers that cover a wide range of topics including business ethics, environmental performance, labor and human rights, and community development. The ESG Guidelines reinforce the principles included in our Supplier Code of Conduct, but go further by requiring that all EPC suppliers submit quarterly reports describing how they managed their ESG performance in the areas listed.

The guidelines expressly prohibit our EPC suppliers from engaging in discriminatory behavior toward, or harassment of, employees, and require that suppliers acknowledge they are subject to anti-corruption and anti-bribery legislation, including the Foreign Corrupt Practices Act, the principles set out in the Organization for Economic Cooperation and Development Convention Combating Bribery of Foreign Public Officials in International Business Transactions (OECD Anti-Bribery Convention), and all other equivalent and applicable anti-corruption and anti-bribery laws.

Clearway prioritizes ethical procurement, with a focus on choosing equipment providers that offer high levels of transparency and traceability in their supply chains. In 2024, these practices meant we were able to complete solar projects on budget and on schedule, while also supporting our customers’ ESG reporting and sustainability goals. In addition, a majority of the equipment we procured for battery energy storage systems (BESS) to be constructed in 2025 was domestically sourced.

In recognition of the significant concerns about human rights abuses and the use of forced labor in the Xinjiang region of China, which produces approximately 50% of the world’s supply of solar-grade polysilicon, we have signed the Solar Energy Industry Association’s Forced Labor Prevention Pledge. We source our solar panels from countries other than China and require our suppliers to affirm that their supply chain practices conform with our requirements.

Clearway team members are actively involved in helping to develop and shape policies and best practices that will contribute to our nation’s clean energy future. Much of this work occurs within trade associations, where our staff participate in committees and working groups and work closely with others in the clean energy industry.

In 2024, many of these efforts were focused on incentives created by the 2022 Inflation Reduction Act (IRA), and in particular, elements of the IRA designed to promote the growth of domestic supply chains for clean energy. Clearway advocated for, and contributed to the development of, guidance from the US Treasury Department regarding the implementation of these incentives.

The guidance clarified aspects of the rules pertaining to the use of domestically sourced content. This in turn has greatly increased confidence among clean energy developers and other market participants, resulting in longer-term planning and driving significant new investments.

We also monitored the development of trade cases affecting the importation of renewable energy equipment into the US, which is important both to mitigate against potential project schedule and budget impacts, as well as to ensure Clearway’s continued compliance with US trade policies.

In addition, we closely followed cases related to the enforcement of laws prohibiting the use of forced labor in the production of materials and equipment used in solar and energy storage projects. This is vital to ensuring Clearway’s sourcing strategies incorporate industry best practices, and critical to upholding our commitment to eliminating forced labor from renewable energy supply chains.

In 2023, Clearway joined the UN Global Compact (UNGC) as well as the UN Global Compact Network USA, the largest corporate sustainability initiative in the world. Our ongoing commitment to our stakeholders is that we will operate responsibly in alignment with UNGC’s Ten Principles, support the communities in which we operate and society at large, and be transparent about our efforts.