Arizona | 000-11412 | 86-0411215 | ||
(State or other jurisdiction | (Commission | (IRS Employer | ||
of incorporation or organization) | File Number) | Identification No.) |
131 S Clark Drive | ||
Tempe, AZ | 85,281 | |
(Address of principal executive offices) | (Zip Code) |
Bradley C. Anderson |
480-967-5146 |
(Name and telephone number, including area code, of the person to contact in connection with this report.) |
[X] | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2014. |
Exhibit Number | Description of Exhibit | |
1.01 | Conflict Minerals Report for the reporting period from January 1, 2014 to December 31, 2014 as required by Items 1.01 and 1.02 of this Form SD. |
Amtech Systems, Inc. | ||
(Registrant) | ||
May 28, 2015 | By: | /s/ Bradley C. Anderson |
(Date) | Bradley C. Anderson | |
Executive Vice President - Finance, Chief Financial Officer, Treasurer and Secretary |
1. | Introduction |
2. | Company Overview |
3. | Reasonable Country of Origin Inquiry |
4. | Due Diligence |
4.1 | Design of Due Diligence Framework |
4.2 | Due Diligence Measures Performed |
4.2.1 | Establish Strong Company Management Systems |
a. | We have a policy regarding the sourcing of conflict minerals, which is publicly available on our company website http://www.amtechsystems.com/governance.htm#conflictminerals. The content of any website referred to in this Report is not incorporated by reference in this Report. |
b. | We have a team that is responsible for organizing our conflict minerals compliance, and that team consists of representatives from Procurement, Finance, Compliance, IT and Source Intelligence® (the “Working Group”). |
c. | We engaged Source Intelligence® to assist us with our supplier engagement and analysis efforts for the Reporting Period. |
d. | Source Intelligence® hosted an e-mail address which allowed our direct suppliers to send us questions about conflict minerals related matters. As needed, Source Intelligence® forwarded Company-specific e-mails to representatives from our Working Group and facilitated communication between our direct suppliers and us. |
e. | Source Intelligence® hosted a conflict minerals supplier resource center that our employees and direct suppliers were able to access to obtain training materials and explanations about the Rule and our conflict minerals compliance program. |
f. | We used the CFSI Conflict Minerals Reporting Template (Revisions 3.00, 3.01 and 3.02) to obtain information on the source and chain of custody of necessary conflict minerals from our direct suppliers. |
g. | Amtech intends to retain relevant supplier response documentation for no less than five (5) years. |
4.2.2 | Identify and Assess Risks in Our Supply Chain |
a. | We sent three hundred sixty-one (361) direct suppliers an e-mail which contained a link to register and complete the CFSI Conflict Minerals Reporting Template and followed up with non-responsive suppliers requesting completion of the template. |
b. | We received a completed CFSI Conflict Minerals Reporting Template from approximately thirty-seven percent (37%) of the direct suppliers from whom we requested completed templates. |
c. | We reviewed our supplier responses and evaluated them for plausibility, consistency, and gaps. We made additional contacts of suppliers to attempt to resolve certain inconsistencies or gaps, including when one or more smelter or refiner was listed for an unused conflict mineral or when a supplier responded that it sourced from a Covered Country but none of the smelters or refiners in its supply chain indicated that they source from a Covered Country. |
d. | We compared the smelters and refiners identified by our suppliers in their completed templates against the CFSI Conflict Free Smelter Program, The London Bullion Market Association Good Delivery List and the Responsible Jewellery Council Chain-of-Custody Certification to determine the certification status of the smelters and refiners and Source Intelligence® further assisted us in validating known smelters and refiners. |
4.2.3 | Design and Implement a Strategy to Respond to Identified Risks |
a. | Our executive management team and relevant members of our Board of Directors are updated annually about our conflict minerals compliance program and any associated risks. |
b. | We sent out an initial notification signed by our President and Chief Executive Officer to each of the three hundred sixty-one (361) suppliers stating the importance of our conflict minerals compliance program. |
4.2.4 | Carry Out Independent Third-Party Audit of Smelters/Refiner’s Due Diligence Practices |
a. | We do not carry out audits of the smelters or refiners identified by our suppliers as being in their supply chain. However, we support audits conducted by third parties by urging our suppliers to gather information from their suppliers in order to accurately complete the Conflict Minerals Reporting Template. |
b. | We rely on industry-wide efforts to encourage smelters and refiners to be audited. |
4.2.5 | Report Annually on Supply Chain Due Diligence |
a. | We publicly report our Conflict Minerals Policy, Form SD and this Report on our company website at: http://www.amtechsystems.com/governance.htm#conflictminerals. |
5. | Results of our Review |
5.1 | Facilities Used to Process the Necessary Conflict Minerals |
a. | Approximately eighty percent (80%) of the responses we received from our direct suppliers were made on a company-level basis, while fifteen percent (15%) were made on a product-level basis and five percent (5%) were on a user-defined basis. Of those made on a product-level or user-defined level, our suppliers named more than one (1) smelter or refiner in their responses for each metal. This lack of detail prevented us from determining whether a particular smelter or refiner named in the responses processed the necessary conflict minerals in our products. Accordingly, we are unable to disclose the facilities used to produce the necessary conflict minerals in our products during the Reporting Period. |
5.2 | Country of Origin of Our Necessary Conflict Minerals |
a. | Based on the responses provided by our suppliers described in section 5.1.a above, the responses did not provide sufficient information to identify the country of origin of the necessary conflict minerals in our products. Accordingly, we are unable to disclose the country of origin of the necessary conflict minerals in our products during the Reporting Period. |
5.3 | Efforts to Determine the Mine or Location of Origin |
a. | We have determined that the most reasonable effort we can make to determine the mines or locations of origin of our necessary conflict minerals is to seek information from our direct suppliers about the smelters and refiners and the countries of origin of the necessary conflict minerals in our products and urge that our suppliers do the same with their direct suppliers. We must rely on our direct and indirect suppliers to provide information about the mine or location of origin of the necessary conflict minerals in our products. |
b. | We were unable to gather the necessary information from these suppliers to determine the mine or location of origin of our necessary conflict minerals. |
6. | Steps Taken and Being Taken to Mitigate Risk |
a. | Continue to engage our direct suppliers and encourage them to obtain responses from their suppliers in order to provide the detailed information needed to identify the source and chain of custody of the necessary conflict minerals in our products. |
b. | Engaged Source Intelligence® to assist us with our supplier engagement and analysis efforts and to identify the country of origin, source and chain of custody of the necessary conflict minerals in our products. |
1. | Forward-Looking Statements |