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Conflict Minerals Policy

Mattson Technology, Inc. is committed to ensure all conflict minerals used in our products do not finance or benefit, directly or indirectly, armed groups in the Democratic Republic of Congo or an adjoining county that are responsible for the on-going conflict in the region and human rights violations. Conflict minerals are defined as cassiterite, columbite-tantalite, gold, wolframite and their derivatives, which are limited to tin, tantalum, tungsten, and gold ("3TG").

We are committed to working with our suppliers to responsibly source any components that contain conflict minerals. We have taken steps to comply with the SEC's ruling relating to conflict minerals, including performing reasonable country of inquiries of our suppliers to verify the origin of any conflict minerals used in the products we are procuring from them. We reserve the right to conduct audits of our suppliers. If we discover that any of the products that we procure contain conflict minerals that are designated as "not conflict free," we expect our suppliers to transition their sourcing to "conflict free" facilities.

Mattson Technology takes very seriously its responsibility to do business in a legal, ethical and conscientious manner, and seeks to comply with both the letter and spirit of the laws and regulations in all countries in which it operates.

Conflict Minerals Report:


California Transparency in Supply Chains Act

In January 2012, the California Transparency in Supply Chains Act of 2010 went into effect. The legislation requires that companies disclose on their websites the actions they are taking to eradicate slavery and human trafficking in their direct supply chains.

Mattson Technology takes very seriously its responsibility to do business in a legal, ethical and conscientious manner, and seeks to comply with both the letter and spirit of the laws and regulations in all countries in which it operates.


Supplier Verification and Certification
  • As part of our supplier approval process, we have certain suppliers complete a supplier evaluation form, which helps us assess potential risks in our supply chain. Our supplier evaluation form includes questions that directly address our suppliers' compliance with applicable laws and regulations. The supplier verification process is performed by Mattson Technology personnel, and not by a third party.

  • In our standard supplier agreement, the supplier warrants that it will comply with all applicable laws, rules or ordinances of the United States or any other governmental agency.

Supplier Audits
  • We reserve the right to conduct audits of our suppliers. To date, we have not engaged in independent, unannounced audits in connection with the California Transparency in Supply Chains Act.

Accountability and Training
  • We maintain a Code of Ethics and Business Conduct which requires our employees and contractors to comply with all applicable laws, rules and regulations in performing their duties for the Company. If an employee or contractor violates the Code of Ethics and Business Conduct, he or she is subject to immediate disciplinary action, including possible termination of employment or affiliation with the Company.

  • On a periodic basis, we provide training to our employees who are responsible for management of our supply chain. This training will familiarize our employees with the issues, risks and challenges related to human trafficking and slavery in the supply chain.



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