Exhibit 1.01
PROTO LABS, INC.
CONFLICT MINERALS REPORT
For the reporting period from January 1, 2025 to December 31, 2025
This Conflict Minerals Report (this “Report”) of Proto Labs, Inc. (the “Company,” “we,” “us” or “our”) has been prepared pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2025 to December 31, 2025.
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products for which the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals, which we collectively refer to in this Report as the “Conflict Minerals,” are gold, columbite-tantalite (coltan), cassiterite and wolframite, or their derivatives, which are limited to tantalum, tin and tungsten. The “Covered Countries” for the purposes of the Rule are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. As described in this Report, the Company manufactures certain products for which the Conflict Minerals are necessary to the functionality or production of those products.
Proto Labs, Inc. Overview
Proto Labs, Inc. is the world's fastest manufacturing service enabling companies across every industry to streamline production of quality parts throughout the entire product life cycle. From custom prototyping to end-use production, we support product developers, engineers, and supply chain teams along every phase of their manufacturing journey. We utilize injection molding, computer numerical control machining, 3D printing and sheet metal fabrication to manufacture custom parts for our customers. Our technology-enabled digital engineering and manufacturing applications enable us to produce commercial-grade prototype and production plastic, metal, and liquid silicone rubber parts in as fast as one day. A very limited number of the metal materials we offer for production of parts have been identified as containing Conflict Minerals (the “Covered Products”).
We have established management systems to support the execution of our Conflict Minerals program and ensure it operates effectively and is sustainable into the future. We have adopted a policy affirming our commitment to conducting business fairly and ethically with respect for human rights and in compliance with applicable laws and regulations, including the Rule, which is available on our website (the “Conflict Minerals Policy”). Our policy also affirms our support for the responsible sourcing of Conflict Minerals through our global supply chain, and states that we are actively and diligently working with our global supply chain partners to determine the origin of any Conflict Minerals they may supply to us, and that we will continue to work with them toward the goal of providing greater supply chain transparency and responsible sourcing. In addition to establishing the Conflict Minerals Policy, we have assembled a cross-functional team to implement and oversee our Conflict Minerals compliance program. We have a process in place to engage our suppliers to educate them about the Rule and request information from them regarding Conflict Minerals, and to collect, analyze and retain any such information received from them.
Reasonable Country of Origin Inquiry
We do not directly source Conflict Minerals. Instead, we purchase raw materials from third-party suppliers that are multiple layers removed from the smelters and refiners of the Conflict Minerals that are in the raw materials ultimately supplied to us. We must therefore rely on our suppliers to provide information regarding the origin of Conflict Minerals that are included in such materials.
For the calendar year 2025 reporting period, we worked with a third-party provider of conflict minerals validation services to assist us in our good faith reasonable country of origin inquiry regarding the Conflict Minerals contained in the products we manufacture. We evaluated the products we manufactured for our customers and determined that certain products manufactured during calendar year 2025 were manufactured with raw materials that may contain Conflict Minerals that are necessary to the functionality or production of those products. We identified 150 suppliers of those raw materials, and surveyed each of them using the Conflict Minerals Reporting Template (the "CMRT”) developed by the Responsible Minerals Initiative (the “RMI”). We requested that these suppliers make
similar inquiries of their suppliers and sub-suppliers until the smelters and refiners of any Conflict Minerals in the raw materials supplied to us could be identified and compared to the smelters and refiners lists developed and maintained by the RMI.
Due Diligence
Due Diligence Design and Framework
Because we could not determine that all the Conflict Minerals in the Covered Products did not originate in a Covered Country or originated from recycled or scrap sources based on the responses to the CMRTs, we exercised due diligence on the source and chain of custody of the Conflict Minerals. The Company’s due diligence measures have been designed to conform to the five-step framework in the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas: Third Edition, including the related supplements on gold, tin, tantalum and tungsten.
Due Diligence Measures Performed
The objective of the due diligence performed was to determine the source and chain of custody of the Conflict Minerals contained in the Covered Products and to determine whether any of those Conflict Minerals are associated with armed groups in the Covered Countries. For the Covered Products manufactured during the calendar year ended December 31, 2025, the Company’s Operations, Compliance and Finance Departments were involved in the due diligence process.
As part of our due diligence, we reviewed supplier responses to each CMRT and followed up with suppliers who did not provide us with a timely response by escalating communication with unresponsive suppliers to the stakeholders in charge of the business relationship via both automated email and personalized email, including offering assistance and further information on how to complete the survey. In reviewing supplier responses, we challenged responses that did not respond on a product level and compared the information reported on the CMRTs to our knowledge of the composition of the materials contained in the Covered Products. We also followed-up on responses to try to get smelters and refiners information so that we could independently verify the information reported on each CMRT. If a supplier identified smelters or refiners in a CMRT, we also screened those smelters and refiners with a screening software to alert us if any materials or components provided to us may have originated in any country that may be subject to sanctions or other various government watchlists related to human rights violations or if any of the smelters or refiners identified are subject to sanctions or may be on other various government watchlists related to human rights violations. If we identity any potential economic sanctions risk as part of this screening process, then we work with the relevant suppliers to evaluate and remediate such risks in a manner consistent with applicable sanctions-program requirements.
Due Diligence Results
Of the suppliers surveyed that returned to us a completed CMRT, we were able to identify 153 smelters and refiners that may have processed Conflict Minerals in materials supplied to us for our Covered Products for 2025. Those smelters and refiners identified by the Company’s suppliers are listed on Annex I below; however, as noted in the introduction to Annex I, this list may be overinclusive given that a few of our suppliers did not report on a product level. 112 of the 153 smelters and refiners reported that the Conflict Minerals in the materials supplied to us for our Covered Products either 1) do not come from the Covered Countries or 2) are conformant to the RMI assurance process for conflict free sourcing. Seventeen of the smelters and refiners are listed as nonconformant, four of the smelters and refiners are listed as active, and twenty of the smelters and refiners are listed as not enrolled. For the 153 smelters and refiners identified by our suppliers that returned a survey, we were not able to identify country of origin data for 23 of those smelters and refiners. Based on the due diligence procedures described above, we are filing this Report as we do not believe the information received from our suppliers and our additional due diligence efforts for calendar year 2025 are sufficient to determine the exact country of origin of the Conflict Minerals in our Covered Products. We are continuing to work with our suppliers to monitor risks in our supply chain to ensure compliance with our Conflict Minerals Policy.
Future Steps to Mitigate Risk
The Company expects to take the following steps, among others, to continue to improve its due diligence measures and to further mitigate the risk that any Conflict Minerals necessary to the functionality of any of the Company’s products finance or benefit armed groups in the Covered Countries: continuing to engage with suppliers to obtain current, accurate and complete information about the supply chain; encouraging suppliers to implement responsible sourcing and to have them encourage smelters and refiners to obtain a “conflict-free” designation from an independent, third-party auditor; and engaging in industry initiatives encouraging “conflict-free” supply chains.
Annex I
The below list of Smelters or Refiners (“SORs”) were identified to the Company by our suppliers as following the RMI protocols for the reporting period from January 1, 2025 to December 31, 2025, with the RMAP Audit Status confirmed as of April 24, 2026. The Company is typically many tiers in the supply chain removed from SORs, and our direct suppliers have not traced materials supplied to us back to individual SORs. Many of our suppliers provided information to the Company on all SORs identified to them by their suppliers, and have not been able to confirm that Conflict Minerals processed by these SORs have been used in the products they have supplied us because they did not provide their CMRT at the product level. Therefore, it is possible that the list contains SORs not used to process Conflict Minerals contained in our products.
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Annex I |
| Smelters and Refiners |
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| Metal | Smelter or Refiner Name | Location (Country) | RMAP Audit Status |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | China | Conformant |
| Tantalum | F&X Electro-Materials Ltd. | China | Conformant |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | China | Conformant |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | Conformant |
| Tantalum | Jiujiang Tanbre Co., Ltd. | China | Conformant |
| Tantalum | AMG Brasil | Brazil | Conformant |
| Tantalum | Metallurgical Products India Pvt., Ltd. | India | Conformant |
| Tantalum | Mineracao Taboca S.A. | Brazil | Conformant |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan | Conformant |
| Tantalum | NPM Silmet AS | Estonia | Conformant |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | Conformant |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | Conformant |
| Tantalum | Taki Chemical Co., Ltd. | Japan | Conformant |
| Tantalum | Telex Metals | United States Of America | Conformant |
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | Conformant |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | Conformant |
| Tantalum | D Block Metals, LLC | United States Of America | Conformant |
| Tantalum | FIR Metals & Resource Ltd. | China | Conformant |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | Conformant |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China | Conformant |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | Conformant |
| Tantalum | KEMET de Mexico | Mexico | Conformant |
| Tantalum | TANIOBIS Co., Ltd. | Thailand | Conformant |
| Tantalum | TANIOBIS GmbH | Germany | Conformant |
| Tantalum | Materion Newton Inc. | United States Of America | Conformant |
| Tantalum | TANIOBIS Japan Co., Ltd. | Japan | Conformant |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | Germany | Conformant |
| Tantalum | Global Advanced Metals Boyertown | United States Of America | Conformant |
| Tantalum | Global Advanced Metals Aizu | Japan | Conformant |
| Tantalum | Resind Industria e Comercio Ltda. | Brazil | Conformant |
| Tantalum | Jiangxi Tuohong New Raw Material | China | Conformant |
| Tantalum | 5D Production OU | Estonia | Outreach Required |
| Tantalum | PowerX Ltd. | Rwanda | Conformant |
| Tantalum | Jiangxi Sanshi Nonferrous Metals Co., Ltd | China | Active |
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
| Tin | Mineracao Taboca S.A. | Brazil | Conformant |
| Tin | Minsur | Peru | Conformant |
| Tin | Operaciones Metalurgicas S.A. | Bolivia (Plurinational State Of) | Conformant |
| Tin | PT Timah Tbk Kundur | Indonesia | Conformant |
| Tin | PT Timah Tbk Mentok | Indonesia | Conformant |
| Tin | Thaisarco | Thailand | Conformant |
| Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil | Conformant |
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia | Conformant |
| Tin | Aurubis Beerse | Belgium | Conformant |
| Tin | Luna Smelter, Ltd. | Rwanda | Conformant |
| Tin | PT Mitra Sukses Globalindo | Indonesia | Conformant |
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| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | Conformant |
| Tin | Alpha Assembly Solutions Inc | United States Of America | Conformant |
| Tin | PT Premium Tin Indonesia | Indonesia | Conformant |
| Tin | Dowa | Japan | Conformant |
| Tin | EM Vinto | Bolivia (Plurinational State Of) | Conformant |
| Tin | Fenix Metals | Poland | Conformant |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | Conformant |
| Tin | China Tin Group Co., Ltd. | China | Conformant |
| Tin | Metallic Resources, Inc. | United States Of America | Conformant |
| Tin | Mitsubishi Materials Corporation | Japan | Conformant |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | Conformant |
| Tin | PT Mitra Stania Prima | Indonesia | Conformant |
| Tin | Rui Da Hung | Taiwan, Province Of China | Conformant |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | China | Conformant |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil | Conformant |
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines | Conformant |
| Tin | PT Rajehan Ariq | Indonesia | Conformant |
| Tin | PT Cipta Persada Mulia | Indonesia | Conformant |
| Tin | Resind Industria e Comercio Ltda. | Brazil | Conformant |
| Tin | Aurubis Berango | Spain | Conformant |
| Tin | PT Bangka Prima Tin | Indonesia | Conformant |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | Conformant |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China | Conformant |
| Tin | Tin Technology & Refining | United States Of America | Conformant |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China | Conformant |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil | Active |
| Tin | CRM Synergies | Spain | Conformant |
| Tin | PT Putera Sarana Shakti (PT PSS) | Indonesia | Conformant |
| Tin | Malaysia Smelting Corporation Berhad (Port Klang) | Malaysia | Conformant |
| Tin | PT Aries Kencana Sejahtera | Indonesia | In Communication |
| Tin | Dongguan Best Alloys Co., Ltd. | China | Conformant |
| Tin | Estanho de Rondonia S.A. | Brazil | Conformant |
| Tin | Jiangxi New Nanshan Technology Ltd. | China | Active |
| Tin | PT Artha Cipta Langgeng | Indonesia | Active |
| Tin | PT Prima Timah Utama | Indonesia | Conformant |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | Non Conformant |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | Non Conformant |
| Tin | Melt Metais e Ligas S.A. | Brazil | Non Conformant |
| Tin | CV Ayi Jaya | Indonesia | Conformant |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam | Non Conformant |
| Tin | An Vinh Joint Stock Mineral Processing Company | Viet Nam | Outreach Required |
| Tin | Super Ligas | Brazil | Conformant |
| Tin | Modeltech Sdn Bhd | Malaysia | Non Conformant |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China | Non Conformant |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | China | Non Conformant |
| Tin | Precious Minerals and Smelting Limited | India | Non Conformant |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | China | Outreach Required |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | Brazil | Conformant |
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| Tin | Mining Minerals Resources SARL | Congo, Democratic Republic Of The | Conformant |
| Tin | Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. | Japan | Conformant |
| Tin | PT Mitra Graha Raya | Indonesia | In Communication |
| Tin | RIKAYAA GREENTECH PRIVATE LIMITED | India | Outreach Required |
| Tin | Woodcross Smelting Company Limited | Uganda | Conformant |
| Tin | Global Advanced Metals Greenbushes Pty Ltd. | Australia | Conformant |
| Tin | Longnan Chuangyue Environmental Protection Technology Development Co., Ltd | China | Outreach Required |
| Tin | P Kay Metal, Inc | United States Of America | Conformant |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China | Non Conformant |
| Tin | Gejiu Kai Meng Industry and Trade LLC | China | Non Conformant |
| Tin | Novosibirsk Tin Combine | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
| Tin | VQB Mineral and Trading Group JSC | Viet Nam | Outreach Required |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam | Outreach Required |
| Tungsten | A.L.M.T. Corp. | Japan | Conformant |
| Tungsten | Kennametal Huntsville | United States Of America | Conformant |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | Conformant |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | Conformant |
| Tungsten | Global Tungsten & Powders LLC | United States Of America | Conformant |
| Tungsten | Japan New Metals Co., Ltd. | Japan | Conformant |
| Tungsten | Kennametal Fallon | United States Of America | Conformant |
| Tungsten | Wolfram Bergbau und Hutten AG | Austria | Conformant |
| Tungsten | Xiamen Tungsten Co., Ltd. | China | Conformant |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China | Communication Suspended - Not Interested |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | Non Conformant |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | Conformant |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | Conformant |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | Conformant |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | Conformant |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | Conformant |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | Conformant |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Viet Nam | Conformant |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | China | Non Conformant |
| Tungsten | H.C. Starck Tungsten GmbH | Germany | Conformant |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | Germany | Conformant |
| Tungsten | Masan High-Tech Materials | Viet Nam | Conformant |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | Conformant |
| Tungsten | Niagara Refining LLC | United States Of America | Conformant |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | China | Conformant |
| Tungsten | Lianyou Metals Co., Ltd. | Taiwan, Province Of China | Conformant |
| Tungsten | Hubei Green Tungsten Co., Ltd. | China | Conformant |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil | Non Conformant |
| Tungsten | Cronimet Brasil Ltda | Brazil | Conformant |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | China | Non Conformant |
| Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | China | Outreach Required |
| Tungsten | Tungsten Vietnam Joint Stock Company | Viet Nam | Conformant |
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| Tungsten | Nam Viet Cromit Joint Stock Company | Viet Nam | Outreach Required |
| Tungsten | Lianyou Resources Co., Ltd. | Taiwan, Province Of China | Conformant |
| Tungsten | Shinwon Tungsten (Fujian Shanghang) Co., Ltd. | China | Conformant |
| Tungsten | Philippine Carreytech Metal Corp. | Philippines | Non Conformant |
| Tungsten | KENEE MINING VIETNAM COMPANY LIMITED | Viet Nam | Conformant |
| Tungsten | Philippine Bonway Manufacturing Industrial Corporation | Philippines | Conformant |
| Tungsten | Hunan Jintai New Material Co., Ltd. | China | Non Conformant |
| Tungsten | Hydrometallurg, JSC | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
| Tungsten | Unecha Refractory metals plant | Russian Federation | Non Conformant |
| Tungsten | Moliren Ltd. | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
| Tungsten | NPP Tyazhmetprom LLC | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
| Tungsten | OOO “Technolom” 2 | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
| Tungsten | OOO “Technolom” 1 | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
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| Annex II |
| List of countries of origin of Conflict Minerals |
| |
| Andorra |
| Angola |
| Argentina |
| Australia |
| Austria |
| Belarus |
| Belgium |
| Bolivia (Plurinational State of) |
| Brazil |
| Burundi |
| Cambodia |
| Canada |
| Central African Republic |
| Chile |
| China |
| Colombia |
| Congo |
| Democratic Republic of Congo |
| Djibouti |
| Ecuador |
| Egypt |
| El Salvador |
| Eritrea |
| Estonia |
| Ethiopia |
| France |
| Germany |
| Guinea |
| Guyana |
| Hong Kong |
| Hungary |
| India |
| Indonesia |
| Ireland |
| Israel |
| Japan |
| Jersey |
| Kazakhstan |
| Korea |
| Liechtenstein |
| Luxembourg |
| Madagascar |
| Malaysia |
| Mali |
| Mexico |
| Mongolia |
| Morocco |
| Mozambique |
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| Myanmar |
| Namibia |
| Netherlands |
| Niger |
| Nigeria |
| Panama |
| Papua New Guinea |
| Peru |
| Philippines |
| Poland |
| Portugal |
| Russian Federation |
| Rwanda |
| Saudi Arabia |
| Sierra Leone |
| Singapore |
| Slovakia |
| South Africa |
| South Sudan |
| Spain |
| Sudan |
| Suriname |
| Sweden |
| Switzerland |
| Taiwan |
| Tanzania |
| Thailand |
| Turkey |
| Uganda |
| United Arab Emirates |
| United Kingdom |
| United States |
| Uzbekistan |
| Viet Nam |
| Zambia |
| Zimbabwe |
