First Solar Inc

# Political Activity Statement

## Compliance, Monitoring and Oversight

The First Solar Code of Business Conduct and Ethics guides us in all that we do. The Code, which is grounded in our Company's values, provides basic guidelines of business practice, as well as professional and personal conduct, that all employees are expected to adopt and uphold. The Code and policies thereunder specifically cover how our employees may engage in the political process and how we interact with representatives of government on behalf of First Solar.

All political activities carried out on behalf of First Solar are managed by the Public Affairs Department, which utilizes a third-party service provider in the administration of its political activity program.  Political contributions using corporate funds are reviewed and approved by the Company's Vice President for State & Local Government Affairs; any contributions above a threshold amount are subject to additional review and approval by the Company's Chief Financial Officer. The Public Affairs Department reports annually to the Nominating and Governance Committee, which is comprised solely of independent members of our Board of Directors, on significant policies and practices concerning political contributions, political contributions made with corporate funds, payments to trade associations which may be used for political purposes, and political activity priorities in light of the Company's public policy objectives.

First Solar maintains a robust government relations and political activity compliance program.  We are committed to complying with internal policies, all relevant state, federal, and international laws and regulations and applicable state and local restrictions on corporate political activity.

First Solar participates in the political process to help shape public policy, legislation and other governmental actions that are consistent with First Solar's business objectives and values. First Solar's VP of Global Policy, Marketing and Sustainability is part of the cross-functional ESG taskforce that is responsible for driving the company's approach to Responsible Solar, including public policy in alignment with the goals of the Paris Agreement among other topics. Our commitment to 'Responsible Solar' drives our company's ESG strategy, advocacy and differentiation and is interwoven into every aspect of our business and product lifecycle- from raw material sourcing to recycling. This includes manufacturing using less energy, water and semiconductor, enabling faster decarbonization through lower embodied carbon, and maximizing resource recovery to enhance circularity. First Solar engages with universities and the wider scientific community to drive our R&D efforts, reduce the environmental footprint of our products, advance PV recycling technology and enhance circularity in line with our commitment to Responsible Solar and our overarching ESG strategy. In our external affairs, we frequently highlight the urgent need for a responsible approach to solar manufacturing, trade and deployment as the fight against climate change accelerates and companies and governments commit to going Net Zero to limit global warming to 1.5 degrees Celsius. How and where solar panels and their components are manufactured determines how many greenhouse gas emissions they will be able to avoid and displace. Our thin film CdTe solar modules manufactured in the US have a carbon footprint that is nearly 4 times lower than conventional crystalline silicon modules manufactured in China. ESG progress updates, including key areas such as public policy, are provided on a quarterly basis to the ESG steering committee, which consists of our executive leadership team. Updates on ESG focus areas including public policy are provided on a biannual or more frequent basis to the Board's Nominating and Governance committee which reviews the Company's ESG strategy, policies and initiatives (other than initiatives delegated to other committees). Public policy and advocacy updates are also provided on a quarterly basis to the full Board of Directors. This comprehensive ESG oversight at the board and executive leadership levels helps ensure alignment across the company.

The Nominating and Governance Committee of the Board of Directors has overall oversight of ESG strategy and policies, which include climate-related issues. The Nominating and Governance Committee periodically reviews the Company's ESG strategy, policies and initiatives, other than initiatives delegated to other committees, and receives updates from the Company's management committee responsible for significant ESG activities. The Audit Committee of the Board of Directors has oversight over risk management for the company. The annual enterprise risk assessment process includes identifying risks that would impact the company's achievement of strategic objectives which includes considering climate-related risks. [...] First Solar's Chief Executive Officer (CEO) has the highest level of direct responsibility for climate change within the company and is the top owner of enterprise risk. In 2020, First Solar identified seven key environmental, social and governance (ESG) focus areas based on our latest materiality assessment: Circular Economy; Energy, Emissions & Resource Efficiency; Inclusion, Diversity & Belonging; Innovative Products; Public Policy & Public Sentiment; Responsible Sourcing and Human Rights; and Reliable Products, and formally established ESG oversight at the board and executive levels. Each key focus area is managed by ESG focus leaders who define, measure and report on progress to the ESG Steering Committee on a quarterly basis. Led by the CEO, the ESG Steering Committee consists of First Solar's Executive Leadership Team, which has the highest level of direct responsibility for ESG matters (which includes our climate change strategy) within the company. The ESG Steering Committee and focus leaders report into the Board of Directors on a biannual or more frequent basis. [...] First Solar's Sustainability and ESG teams coordinate the ESG focus groups and work cross-functionally to identify climate-related and other ESG risks as part of the company's enterprise risk management process. This includes modelling climate scenarios to identify potential future risks and opportunities. [...] The Energy, Emissions, and Resource Efficiency working group is responsible for measuring and monitoring progress of First Solar's resource efficiency and climate change strategy. This includes monitoring the implementation of our RE100 goal, setting science-based greenhouse gas emissions targets as well as energy and water targets.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]First Solar's VP of Global Policy, Public Sentiment and Sustainability is part of the cross-functional environmental, social, and governance (ESG) taskforce that is responsible for identifying strategic ESG risks, opportunities, gaps and challenges, anticipating ESG trends that could impact the company, and proposing new ESG policies, practices, targets, metrics and disclosures. First Solar's ESG focus leaders help advance the company's approach to Responsible Solar by driving progress on key strategic ESG areas including Public Policy and Public Sentiment among other topics.

Our commitment to 'Responsible Solar' drives our company's ESG strategy and differentiation and is interwoven into every aspect of our business and product lifecycle- from raw material sourcing to end-of-life recycling. This includes manufacturing using less energy, water and semiconductor, enabling faster decarbonization through lower embodied carbon, and maximizing resource recovery to enhance circularity. First Solar engages with universities and the wider scientific community to drive our R&D efforts, reduce the environmental footprint of our products, advance PV recycling technology and enhance circularity in line with our commitment to Responsible Solar and our overarching ESG strategy.

In our external communications, we frequently highlight the urgent need for a responsible approach to solar manufacturing and deployment as the fight against climate change accelerates and companies and governments commit to going Net Zero to limit global warming to 1.5 degrees Celsius. How and where solar panels and their components are manufactured determines how many greenhouse gas emissions they will be able to avoid and displace. Our thin film CdTe solar modules manufactured in the U.S. have a carbon footprint that is 2.5 times lower than conventional crystalline silicon modules manufactured in China.

ESG progress updates, including key areas such as public policy, are provided on a quarterly basis to the ESG steering committee, which consists of our executive leadership team. Updates on ESG focus areas including public policy are provided on a biannual or more frequent basis to the Board's Nominating and Governance committee which, pursuant to its charter, reviews the Company's ESG strategy, policies and initiatives (other than initiatives delegated to other committees). This ESG oversight at the board and executive leadership levels helps ensure alignment across the company.