Myomo Inc.

05/28/2026 | Press release | Distributed by Public on 05/28/2026 14:25

Specialized Disclosure Report (Form SD)

Conflict Minerals Report of

Myomo, Inc.

For the Year Ended December 31, 2025

Introduction

This is the Conflict Minerals Report (the "CMR") of Myomo, Inc. (the "Company," "we" or "us" or "our") for the reporting period from January 1, 2025 to December 31, 2025 in accordance with Rule 13p-1 (the "Rule") under the Securities Exchange Act of 1934, as amended (the "1934 Act"). The Rule requires disclosure of certain information when a registrant manufactures or contracts to manufacture products that contain, or likely contain, the "Conflict Minerals" specified in the Rule, which are necessary to the functionality or production of products (the "Covered Products"). We have six Covered Products, which are left and right versions of our MyoPro® Motion W and Motion G, and left and right versions of our MARK (Mobile Arm Rehab Kit) units, including accessories provided therewith.

"Conflict Minerals" are defined as gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten. Tantalum, tin, tungsten and gold are collectively referred to as "3TG" for the purposes of this assessment. According to the Rule, if a registrant, based on a good faith reasonable country of origin inquiry regarding the Conflict Minerals, has reason to believe that (i) the Conflict Minerals contained in its Covered Products may have originated in the Democratic Republic of the Congo ("DRC") or an adjoining country (collectively with the DRC, the "Covered Countries") or (ii) such Conflict Minerals may not be from entirely recycled or scrap sources, then the registrant must exercise due diligence on the source and chain of custody of the Conflict Minerals, and submit a conflict minerals report describing those due diligence measures.

Reasonable Country of Origin Inquiry

During the year ended December 31, 2025, we conducted a Reasonable Country of Origin Inquiry ("RCOI") to determine, using good faith and reasonable best efforts, whether any of the necessary 3TG that was necessary to the production or functionality of our Covered Products in 2025 originated, or likely originated, from any of the Covered Countries or whether the 3TG originated, or likely originated, from entirely recycled or scrap sources. We held meetings with our engineering and supply chain functions to review the bill of materials for our products to determine which of our purchased components may contain 3TG and to map them their respective suppliers.

We believe that the number of suppliers that may use 3TG in the manufacture of our purchased components is limited. We identified 28 relevant suppliers. We requested that all identified suppliers provide information regarding the origin of the Conflict Minerals contained in components supplied using version 6.5, or higher, of the Conflict Minerals Reporting Template ("CMRT") of the Responsible Business Alliance and created by the Responsible Minerals Initiative ("RMI").

We reviewed the responses received, checked for inconsistencies, incomplete forms, and inaccurate responses, and sent reminders to suppliers who did not respond to our requests for information. We compared the Conflict Minerals smelters or refiners reported in the surveys returned against the lists of facilities that received a conformant or active designation by the RMI's Responsible Minerals Assurance Process ("RMAP"). In accordance with the Rule, we concluded in good faith that during the year ended December 31, 2025:

Our products include certain purchased components for which Conflict Minerals are necessary to the functionality or production of those products; and

Based on our good faith RCOI regarding the Conflict Minerals, we had reason to believe that: (i) the Conflict Minerals contained in our Covered Products may have originated in the DRC or one or more of the Covered Countries and (ii) such Conflict Minerals are not from entirely recycled or scrap sources.

Myomo Inc. | 45 Blue Sky Dr., Suite 101 | Burlington, MA 01803

TEL: 877.736.9666 www.myomo.com [email protected]

As a result, we exercised due diligence on the Conflict Minerals' source and chain of custody and are filing this CMR with our Form SD to comply with the requirements of the Rule. In accordance with applicable guidance from the U.S. Securities and Exchange Commission (the "SEC"), we are not required to obtain an independent private sector audit of our CMR for the year ended December 31, 2025. The due diligence measures we performed are discussed below.

Part I. Company Overview and Description of the Company's Products Covered by This Report


We are a wearable medical robotics company, specializing in myoelectric braces, or orthotics, for people with neuromuscular disorders. We develop and market the MyoPro product line, which is a myoelectric-controlled upper limb brace, or orthosis. The orthosis is a rigid brace used for the purpose of supporting a patient's weak or deformed arm to enable and improve functional activities of daily living ("ADLs"), in the home and community. It is custom constructed by trained personnel during a custom fabrication process for each individual user to meet their specific needs. Our products are designed to help restore function in individuals with neuromuscular conditions due to brachial plexus injury, stroke, traumatic brain injury, spinal cord injury and other neurological disorders.

Part II. The Company's Due Diligence Process

Design of Due Diligence

We have adopted due diligence processes in accordance with Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition (2016), including the related Supplements on Tin, Tantalum and Tungsten and on Gold published by the Organization for Economic Co-Operation and Development (collectively, the "OECD Guidance").

The design of our Conflict Minerals program is in conformity with the OECD Guidance, specifically as it relates to our position in the minerals supply chain as a company that is several levels removed from the actual mining of Conflict Minerals (i.e., a "downstream company"). We do not make direct purchases of raw ore or unrefined Conflict Minerals and instead rely on our direct suppliers to provide us with the information regarding the likely source and chain of custody of the 3TG minerals supplied to us. Summarized below are the design components of our Conflict Minerals program as they relate to the five-step framework set forth in the OECD Guidance:

Due Diligence Performed

Step 1. Establish Strong Company Management Systems

Internal Compliance Team.

Senior management is involved with the overall execution of our program. The compliance team consists of members of the Engineering and Supply Chain departments. This team is responsible for reviewing supplier data and coordination of issues and other tasks that may arise. The team is also responsible for following up with non-responsive suppliers. The team, together with the chief financial officer, reviews our data collection efforts.

Control Systems

We rely on our direct suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us - including sources of 3TG that are supplied to them from lower tier suppliers. To obtain this information from our suppliers, we retained a third-party service provider, ComplianceXL to assist us in collecting and reviewing this data. CMRT's were requested of suppliers whose products may contain 3TG as identified by our Internal Compliance Team. We expect all our suppliers to have policies and procedures in place to ensure that any 3TG minerals used in the production of the products sold to us are DRC conflict-free. This means that the products must not contain 3TG minerals that directly or indirectly finance, or benefit armed groups in the Covered Countries. These expectations are communicated directly to suppliers. These efforts are made more difficult due to the fact that a significant portion of our supply chain is not required to file reports with the SEC under Sections 13(a) or 15(d) of the Exchange Act.

Myomo Inc. | 45 Blue Sky Dr., Suite 101 | Burlington, MA 01803

TEL: 877.736.9666 www.myomo.com [email protected]

Other controls include, but are not limited to, our Code of Business Conduct and Ethics that outlines certain expected behaviors for all employees. The Code of Conduct is available to all direct suppliers and if a supplier does not meet our requirements, the relationship with this supplier will be evaluated. Our Code of Conduct is reviewed annually to ensure it continues to align with industry best practices.

Strengthen the Company's Engagement with Suppliers

We inform our in-scope manufacturers and suppliers of our disclosure requirements, including our compliance with the OECD Guidance and the Rule.

We have implemented a supply chain system of controls and transparency through the use of due diligence tools created by the RMI. These tools include, as discussed in "Step 2" below, accepting at a minimum version 6.5, or higher, of the CMRT, which is designed to identify and verify information regarding the smelters or refiners that process the necessary Conflict Minerals contained in our products.

Establish a Company-level Grievance Mechanism.

We maintain a telephonic and internet-based hotline for all employees. The hotline is available for use with respect to Conflict Minerals. An independent company (the, "Contractor") receives calls and electronically submitted tips and issues. The Contractor will notify the CEO, CFO, General Counsel, and Chair of the Audit Committee of the Board of Directors of any calls or other submissions. Upon notification, we evaluate the best method of investigation, evaluation, and if required resolution of any matters. Any matters submitted are reviewed by the Audit Committee during their quarterly meetings.

Maintain Records

We have adopted a policy to retain relevant documentation for a period of 5 years, including supplier responses to CMRTs. We store all of the information and findings from this process in an internal file management system that can be audited by internal or external parties.

Step 2. Identify and Assess Risks in the Supply Chain

Identify Risks in the Supply Chain by Identifying Company Suppliers.

Identify Company Suppliers.

As explained above, we do not buy raw ore or unrefined Conflict Minerals directly from refiners, smelters or mines. Our supply chain with respect to the Covered Products is complex, with multiple intermediaries and third parties in the supply chain between the manufacturing of the Covered Products and the original sources of the necessary Conflict Minerals. Because we believe that the smelters or refiners of the Conflict Minerals are best situated to identify the sources of Conflict Minerals, we rely on our direct suppliers to provide information on the origin of the Conflict Minerals contained in components and materials supplied to us.

As discussed above under "Reasonable Country of Origin Inquiry" and "Part I. Company Overview and Description of the Company's Products Covered by This Report," we identified our Covered Products falling within the scope of the Rule (i.e., products which were manufactured or contracted to be manufactured by us) during the 2025 calendar year. Based on these Covered Products, we were able to identify the suppliers from which we purchase components or materials for the Covered Products that may include Conflict Minerals. We identified 28 relevant suppliers whose products may contain 3TG.

Request Conflict Minerals Reporting Templates (CMRTs) from suppliers.

Myomo Inc. | 45 Blue Sky Dr., Suite 101 | Burlington, MA 01803

TEL: 877.736.9666 www.myomo.com [email protected]

We surveyed these suppliers to identify the 3TG contained in the products they supply us with, the smelters or refiners that process the 3TG and the country of origin, or likely country of origin, of such 3TG. The survey was conducted by our third party service provider utilizing version 6.5, or higher, of the CMRT. We utilize this RMI reporting template to collect data and information from our suppliers in order to identify the origins of 3TG in our supply chain. We received responses from all 28 of surveyed suppliers (100%).

Assess Risks in the Supply Chain.

Analyze surveys for RMAP "conformant" and "active" smelters or refiners.

We compared smelters or refiners identified in the supply chain survey against the RMI's "conformant" smelter or refiner list, which lists all facilities that have received a RMAP "conformant" designation from the RMI. We reviewed all of the responses to determine whether smelters or refiners identified in our supply chain obtained a designation of "conformant" or "active" from the RMI.

Of the CMRT responses we received from suppliers, some included incomplete responses as well as inconsistencies and inaccuracies within the reported data. In such cases, we contacted the suppliers directly in an effort to secure revised responses. In some cases, if Company-level CMRT's resulted in responses noting use of Conflict Minerals in the Covered Products, we attempted to seek product-level CMRT's to confirm the responses. Through this process, we have identified, to the best of our efforts, the smelters or refiners in our supply chain and country of origin, or likely country of origin, based on information for the smelters or refiners identified in the supply chain survey.

Understand and define RMAP "conformant" and "active" statuses.

To compile its list, the RMI employs independent third-party auditors to audit the source, including mines of origin and chains of custody, of the Conflict Minerals processed by smelters or refiners which agree to undergo an audit. "Conformant" means that a smelter or refiner was listed as "conformant" with the RMAP's assessment protocols, including those indicated as "re-audit in progress".

Smelters or refiners labeled as "active" have committed to undergo an audit, which may be in progress, or are participating in one of the cross-recognized certification programs, namely, the London Bullion Market Association ("LBMA") Responsible Gold Certification or Responsible Jewelry Program Chain-of-Custody Certification.

Step 3. Design and Implement a Strategy to Respond to Identified Risks

We deal with each supplier on an individual basis as our response to suppliers is dependent on the risk(s) identified and exposure. Factors considered include the overall willingness of the supplier to mitigate risk as well as our ability to procure alternative suppliers. Our response is measured and does include termination of our relationship, if necessary

Step 4. Carry Out Independent Third-Party Audit of Smelter/Refiner's Due Diligence Practices

Due to our downstream position in the supply chain, we do not have a direct relationship with 3TG smelters or refiners. Therefore, we do not perform direct audits of these entities within our supply chain, but instead rely on the efforts of organizations such as the RMI to influence smelters or refiners to undergo audits and become certified through the RMAP.

Step 5. Report Annually on Supply Chain Due Diligence

Our supply chain due diligence efforts are described in this CMR. We have filed this CMR in accordance with the Rule by filing a Form SD with the SEC, with this CMR as an exhibit. This CMR is also available on our website at https://ir.myomo.com/corporate-governance/governance-documents. Information contained on, or that can be accessed through, our website does not constitute a part of this CMR and is not incorporated by reference herein.

Myomo Inc. | 45 Blue Sky Dr., Suite 101 | Burlington, MA 01803

TEL: 877.736.9666 www.myomo.com [email protected]

Part III. The Company's Due Diligence Findings and Conclusions

Our Conflict Minerals process, as described above, allowed us to identify in-scope products and the corresponding suppliers. These 28 identified suppliers were surveyed using version 6.5, or higher, of the CMRT. We received survey responses from all 28 (100%) of our surveyed suppliers. 12 suppliers reported use of 3TG in the products we purchase from them. Of those suppliers, 5 suppliers reported that the 3TG minerals used in the products that we purchase from them were not sourced from a Covered Country. The remaining 7 suppliers reported that the products they provide to us contain 3TG minerals, which may have been sourced from the Covered Countries. Of these remaining 7 suppliers, despite our due diligence, for 5 of the suppliers, we were not able to make definitive conclusions as to the source or likely source of any potential Conflict Minerals that were necessary to the production or functionality of our products that were manufactured, or contracted to manufacture, in 2025. For the remaining 2 suppliers, we were able to obtain product-level CMRT's and were able to conclude that those suppliers are using 3TG minerals from Covered Countries in the manufacturing of components used in our products, however we were able to determine that the 3TG were sourced from the RMI Compliant smelters.

Facilities Used to Process the Conflict Minerals in the Covered Products

We compared the list of smelters and refiners provided in our suppliers' responses to the lists of smelters maintained by RMI and, if a supplier indicated that a facility was certified as conflict-free, confirmed that the facility was listed on RMI's list of validated conflict free smelters and refiners of 3TG. Our suppliers identified a total of 224 legitimate smelters and refiners that appear on the lists maintained by RMI. Based on the smelter list provided by suppliers via the CMRT and publicly available information, we have identified 218 smelters and refiners that are deemed RMI Compliant. We identified 6 smelters deemed RMI Active. Most of the CMRTs we received were made on a company or division level basis, which did not allow us to identify which smelters or refiners listed by our suppliers actually processed the 3TG contained in our products. We attempted to obtain product-level CMRT's as appropriate. All smelters and refiners identified by our suppliers that we believe may source 3TG from the Covered Countries appear on RMI's list of validated conflict free smelters and refiners. Attached, as Annex I, is a list of all of the smelters and refiners listed by our suppliers in their completed CMRTs that appear on the lists of smelters maintained by the RMI as legitimate.

Part IV. Implementation of Strategies to Respond to Current Year Findings, Identified Risks and Future Steps

As noted in Part III, 2 suppliers were identified where 3TG minerals sourced from Covered Countries were included in the components we purchase from those suppliers. However, we determined that the 3TG were sourced from RMI Compliant smelters. We intend to monitor all of our suppliers to ensure 3TG for our purchased components continue to be obtained from legitimate suppliers, to the extent possible.

We have taken, and intend to continue taking, steps to improve our due diligence processes and to minimize the risk that our necessary Conflict Minerals benefit, or likely benefit, armed groups in the DRC or Covered Countries, as well as Conflict-Affected or High-Risk Areas. Going forward, we will continue working with our global supply chain to ensure responsible sourcing and assure compliance with applicable regulations through the following steps:

1.

Contacting from time to time, as is reasonably required, direct suppliers that do not respond to the supply chain survey by a specified date, requesting their responses.

2.

Comparing, as is reasonably required, applicable smelters or refiners identified in the supply chain survey against the list of facilities that have received a RMAP "conformant" or "active" designation from the RMI's RMAP.

3.

Making a good faith effort to enact terms and conditions related to Conflict Minerals in supplier contracts.

4.

Engaging with suppliers to encourage them to provide requested information for 2026.

Myomo Inc. | 45 Blue Sky Dr., Suite 101 | Burlington, MA 01803

TEL: 877.736.9666 www.myomo.com [email protected]

5.

Continuing to communicate to our suppliers the expectation that they steer their supply chain towards "conformant" smelters as defined by the RMI's RMAP or other equivalent programs.

Myomo Inc. published this content on May 28, 2026, and is solely responsible for the information contained herein. Distributed via EDGAR on May 28, 2026 at 20:25 UTC. If you believe the information included in the content is inaccurate or outdated and requires editing or removal, please contact us at [email protected]