Conflict Minerals

Amtech is a publicly-traded company, and, therefore, subject to the conflict mineral reporting obligations that arise from Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Section 1502”) issued by the U.S. Securities and Exchange Commission (“SEC”) in 2012. Section 1502 obligates companies publicly traded in the U.S. to disclose the use of conflict minerals, which is inclusive of tantalum, tin, tungsten and gold, originating in the Democratic Republic of the Congo or any adjoining country (collectively, the “Covered Countries”) in the products that they manufacture or contract to manufacture. Complying with Section 1502 is a priority for us, and, therefore, we have established a Conflict Minerals Policy and supplier reporting process to aid in our compliance.

Amtech’s supply chain is large and complex, consisting of approximately one thousand direct suppliers. We expect our suppliers to take reasonable steps to identify and assess risk in their supply chain in order to ensure that conflict minerals originating from the Covered Countries are not used in products supplied to Amtech. Additionally, we expect our suppliers to cooperate and assist us with our due diligence measures by providing timely, complete and accurate information by use of the Conflict Minerals Reporting Template developed by the Responsible Minerals Initiative.

Amtech is committed to complying with industry guidance and the conflict minerals reporting obligations required under Section 1502. If, through our risk assessment and review, Amtech identifies suppliers that have failed to comply with our Conflict Minerals Policy, Amtech will take appropriate actions, including evaluating the continuation of the business relationship with the supplier.

Suppliers and other external parties are invited to contact Amtech at compliance@AmtechGroup.com for further guidance or to report concerns regarding conflict minerals.

If you wish to file an anonymous suggestion or complaint, you can contact our Ethics Hotline by phone in the United States at 833-940-2879 or through The Ethics Web Portal.

Here is a link to our most recent Form SD filed with the SEC:

• 2019 Conflict Minerals Report and Form SD