CONFLICT MINERALS

We are aware of the conflict minerals reporting obligations that arise out of the rule issued by the U.S. Securities and Exchange Commission (“SEC”) in 2012. Amtech Group is an SEC reporting company, and the conflict minerals rule applies to us. Complying with the rule is a priority, and therefore we have implemented a process to determine the source and country of origin of the conflict minerals in our products.

We have determined that conflict minerals are necessary to the functionality and/or production of certain of our products. We are now in the process of trying to determine the country of origin of these conflict minerals and to determine whether these minerals originated in the Democratic Republic of Congo or adjoining countries. We are making inquiries of our supplier community to obtain the necessary information about the source of these conflict minerals. As you know, this process requires the cooperation of many entities in our supply chain. We will need additional time to complete our inquiry and to review of the information that our suppliers provide to us.

We want to assure you that we understand the importance of this issue to you, and we will continue to take actions to manage our supply chain with respect to conflict minerals. After we have gathered the necessary information from our supply chain, we will be able to respond more fully to your inquiry. You can read a copy of the Form SD filed with the SEC here:

2013 Conflict Minerals Report and Form SD 
2014 Conflict Minerals Report and Form SD 
2015 Conflict Minerals Report and Form SD 
2016 Conflict Minerals Report and Form SD 

If you have any further questions or concerns, you can contact us by email at compliance@AmtechGroup.com

If you wish to file an anonymous suggestion or complaint, you can contact our Ethics Hotline by phone in the United States at 866-413-1994 or through The Ethics Web Portal