Exhibit 1.01

Conflict Minerals Report of SCHMID Group N.V.
For The Year Ended December 31, 2024

Introduction

This Conflict Minerals Report for SCHMID Group N.V. (“SCHMID”, “we”, “us” or “our”) covers the reporting period from January 1, 2024 to December 31, 2024, and is filed in compliance with Rule 13p-1 of the Securities Exchange Act of 1934 (the “Rule”). The Rule was adopted by the Securities Exchange Commission (the “SEC”) to implement reporting requirements related to conflict minerals. Conflict minerals are defined under the Rule as columbite-tantalite (coltan), cassiterite, wolframite, gold and their derivatives, which are currently limited to tin, tantalum and tungsten (“Conflict Minerals”). This Conflict Minerals Report (“CMR”), filed as Exhibit 1.01 to our Specialized Disclosure Report on Form SD, is focused on the minerals tin, tantalum, tungsten and gold, as these are the Conflict Minerals that we use to manufacture our products and that are needed for our products to function.

Form SD provides that if Conflict Minerals are necessary to the functionality or production of a product manufactured by an SEC registrant, such registrant is required to conduct in good faith a reasonable country of origin inquiry (“RCOI”) that is reasonably designed to determine whether any such Conflict Minerals that are necessary to the functionality or production of products originated in the Democratic Republic of the Congo or an adjoining country (collectively, the “Covered Countries”), and such registrant is also required to describe the RCOI and disclose the results thereof.

We need certain Conflict Minerals to manufacture our products, and our products need certain Conflict Minerals to function. We are committed to responsible sourcing of materials in our supply chain and support international efforts to ensure the mining and trading of Conflict Minerals from conflict-affected and high-risk areas does not contribute to conditions of armed conflict and/or serious human rights abuses in the DRC or its adjoining countries as defined in Form SD.

Statements in this CMR are based on our RCOI and our due diligence activities performed in good faith for the reporting period from January 1, 2024 to December 31, 2024 and are based on information available at the time of this filing, unless otherwise indicated.

Business Overview

We are a global supplier of equipment, software and services for various industries such as printed circuit board (“PCB”), substrate manufacturing, photovoltaics, and glass and energy storage with a focus on the highest end of this market in terms of technology and performance. We are a long-established, fifth- generation family-controlled business that was founded in 1864 in Freudenstadt, Germany as an iron foundry and has a tradition of being at forefront of technology. Throughout the 160 years of our operations, we have maintained sustainable operations by developing our products following trends on the market. We have been developing machines for electronics industry since the 1960s, photovoltaics solutions since the early 2000s and energy storage for the last ten years. We are a global supplier of capital equipment, software and services for the PCB and substrate manufacturing industry. We do not only develop production techniques and build machines ourselves, we are also extensively working with our customers on joint research and development projects for the next generation of electronics and photovoltaics products.

We produce our products in two manufacturing sites, one in Germany and one in China. In addition, we have built up an extensive service and sales network in five centers in the US, Europe, and Asia. In addition to our sale and service centers and two manufacturing sites, in South Korea we also work with our partners in the SCHMID Avaco Korea, Co. Ltd.. We also provide customer service through which we assist our customers with machinery and software upgrades, spare parts, logistics, customer training in multiple languages, on-site management, maintenance contracts and project management.

Product Portfolio and Use of Conflict Minerals

Like many companies in our industry, our products contain certain minerals and metals necessary to the functionality or production of our products, including Conflict Minerals. Conflict Minerals are important components in certain electronic parts, without which our products would not work. Conflict Minerals can be contained in our circuit boards, nozzles (tungsten-carbonite) or frequency converters in particular.

Our supply chain

We outsource the production of several components that are necessary for the manufacturing of our products. Therefore, we collaborate with our suppliers for the development, manufacturing and delivery of unique parts and modules. In particular, we do not engage in the manufacturing of electronic components that may contain Conflict Minerals ourselves. We source any such electronic components from selected manufacturers.

The sourcing of Conflict Minerals used in our products goes beyond our tier 1 suppliers. There are several tiers of suppliers between SCHMID and any smelter of Conflict Minerals, and even more tiers when tracing a mineral or metal all the way back to the mines of origin. Under no circumstances do we assemble Conflict Minerals directly and therefore do not purchase Conflict Minerals as a raw material from smelters or miners. Therefore, we do not have any direct purchasing relationship with miners or smelters.

Due Diligence Program

We base our due diligence measures on the guidelines of the five-step framework set forth by the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Guidance”) as summarized below.

1. Establish strong management systems

Policy

Conflict Minerals are addressed in our Supplier Code of Conduct, which forms part of our General Purchasing Conditions. The objective of this Supplier Code of Conduct is to forward the values that we pursue to all of our business partners, to ensure that all activities are conducted on the same ethical grounds. In addition, our position on Conflict Minerals is reflected in our company-wide Code of Conduct, which incorporates our Human Rights Policy as well as our Anti-Bribery and Anti-Corruption Policy. The documents are available on our company website. Please note that the website and the information accessible through it are not incorporated by reference into this Form SD.

Governance

To ensure compliance with our policies, the Legal & Compliance team defines a structured approach aligned with SCHMID’s commitment to responsible sourcing of Conflict Minerals. This includes conducting a RCOI and implementing due diligence measures in accordance with applicable regulations and internationally recognized guidelines. The results of our due diligence activities are monitored and reviewed by members of the Legal & Compliance team and discussed with members of senior management.

Control system

The Supplier Code of Conduct and the associated obligations and responsibilities of our suppliers form an integral part of every purchase order we issue. As part of our General Purchasing Conditions, all suppliers are required to accept our Supplier Code of Conduct. This ensures that we only work with suppliers who have systems in place to guarantee the sourcing of conflict-free minerals for our electronic components. We maintain business relationships exclusively with reputable partners who also comply with anti-money laundering and anti-terrorism regulations.

In addition, we require selected suppliers of electronic components to verify their handling of Conflict Minerals (tin, tantalum, tungsten, and gold) and to demonstrate how they ensure compliance with internationally recognized regulations. We only purchase electronic components (in which we suspect Conflict Minerals) from suppliers who we have gained the confidence that they handle the purchase of Conflict Minerals responsibly.

Supplier engagement

In general, we expect our suppliers to always check their products to determine whether they are subject to prohibitions, restrictions, information obligations and/or approval requirements in the international movement of goods. In relation to Conflict Minerals, we expect our Suppliers to have policies in place to reasonably assure that any Conflict Minerals used in the production of the products sold to us are conflict-free. This means that the products do not contain Conflict Minerals that directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in the Covered Countries.

Grievance mechanism

We encourage everyone, including suppliers and other stakeholders to express, in good faith, any concerns they might have regarding possible violations of our Code of Conduct, our company’s policies or the law. Information on suspected compliance cases and questions can be sent to the legal department via the compliance email address and the whistleblower system in place. SCHMID will investigate all reports and take appropriate action.

2. Identify and assess risk in the supply chain

Our supply chain conflict mineral due diligence is risk based, as described in the bullet points below:

3. Design and implement a strategy to respond to identified risks

Our risk management plan is intended to respond to situations where Conflict Minerals contained in our in-scope products are identified as potentially sourced from the Covered Countries, as well as other risks that are identified during our due diligence process.

Our plan includes:

4. Carry out independent third-party audit

We rely on third party audits of smelters and refiners such as those carried out through the RMI’s Responsible Minerals Assurance Program (“RMAP”). To the extent that other audited supplier certifications are provided to the company, the company may consider reliance on a case-by-case basis.

5. Report on supply chain due diligence

We report to the SEC annually our supply chain due diligence on a Form SD and Conflict Minerals report. In addition, we publicly communicate our Form SD and Conflict Minerals report on our company website.

Description of Due Diligence Measured Performed

Due diligence for the RCOI has been performed in a manner consistent with the OECD Guidance as described above in the section “Due Diligence Program”. SCHMID regularly reviews and revises its supply chain due diligence processes with the aim of incorporating learnings from practice, feedback from stakeholders and requirements from standards and regulations.

Results of the Due Diligence

With the support of our product experts, we executed a scoping assessment to determine which certain products manufactured during calendar year 2024 were manufactured with materials or components that contain, or likely contain, Conflict Minerals. This information together with the direct spending volumes were input to select those suppliers.

We asked these in-scope suppliers to provide information about the smelters of Conflict Minerals used in our products. We assessed the responses received from our in-scope suppliers for red flags, completeness and reasonableness. We then communicated with in-scope suppliers about their responses.

From our key suppliers we received Conflict Minerals Reporting Templates that were prepared in accordance with the standardized reporting template created by the Responsible Minerals Initiative (RMI). However, some other suppliers have either failed to provide the requested information or submitted documentation that was incomplete.

Appendix A includes a list of the entities that were identified by our suppliers as the smelters or refiners that process the necessary Conflict Minerals in the suppliers’ products. Of those 360 smelters and refiners, 229 have been identified by the RMI as “conformant” with the RMAPs third-party audit protocol, and another four have been identified by the RMI as “active,” meaning they have agreed to undergo or are currently undergoing a third-party audit and are progressing through the audit and/or post-audit corrective action process. The remaining 127 smelters and refiners fall under the RMI “not active” category, meaning that their conformance status is unknown, cannot be verified, or that they are possibly non-conformant. Since some of the declarations we received from our suppliers were at a company level (and not a component-specific level), we do not know with certainty that each smelter listed on Appendix A actually processed Conflict Minerals that were used in components we purchased.

Results of the Reasonable Country of Origin Inquiry

In accordance with the Rule, SCHMID conducted in good faith a RCOI to determine whether any of the Conflict Minerals that are necessary to the functionality and production of our products may have originated in the Covered Countries.

Because the information that we obtained from our in-scope suppliers was incomplete, we were unable to fully determine the countries of origin of the Conflict Minerals or the facilities used to process them.

The results of the RCOI indicated that some of the Conflict Minerals necessary to the functionality or production of our products may have originated in the Covered Countries and may not be derived from recycled or scrap sources.

Continuous Improvements

In 2025, we plan to expand and improve the due diligence conducted with respect to our supply chain. We will consistently remind our suppliers of their obligations and our expectations regarding Conflict Minerals reporting. This ongoing communication is crucial to ensure that all parties are aligned and aware of the importance of this issue. We also aim to engage more actively with our suppliers to increase the number of the response rate and improve the quality of the survey responses. This will help us gather more accurate and comprehensive data.

Cautionary Statements

This CMR contains statements obtained in reliance to information provided by our suppliers through our RCOI as well as our due diligence measures. We have no direct relationships or power of control over mines, smelters, or refiners. Therefore, we rely on our suppliers for the ultimate veracity of the information which they provide about the smelters or refiners whom they employ, and such information may be inaccurate, incomplete, or subject to other irregularities. Additionally, despite our continuous efforts, we may be unable to determine the precise (country of) origin of the Conflict Minerals, included in all our products, or the facilities used to process them, due to Conflict Minerals supply-chain complexities and the number of tiers of suppliers to trace the source.