Lifeward Ltd.

05/29/2026 | Press release | Distributed by Public on 05/29/2026 14:06

Specialized Disclosure Report (Form SD)


Conflict Minerals Report of
Lifeward Ltd.
For the year ended December 31, 2025

Introduction
This is the Conflict Minerals Report (the "CMR") of Lifeward Ltd. (the "Company," "we" or "us" or "our") for calendar year 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").

"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 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 management from various departments to discuss the applicable definitions of "manufacturer" and/or "contract to manufacture." By way of this process, we identified specific types of product parts within our products that contain within them 3TG that is necessary to their production or functionality and mapped them to their respective suppliers.
We developed a risk-based approach that focuses on our key suppliers involved in manufacturing the majority of our finished products. We identified 80 relevant suppliers. We contracted a third-party service provider to assist us with the survey of suppliers. Through this third-party service provider, we sent letters to our relevant suppliers. We requested that all identified suppliers provide information regarding the origin of the Conflict Minerals contained in products 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 with the 80 suppliers 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:

Certain of our operations manufactured, or contracted to manufacture, products 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 may not be from entirely recycled or scrap sources.

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 medical device company that designs, develops, and commercializes life-changing solutions that span the continuum of care in physical rehabilitation and recovery, delivering proven functional and health benefits in clinical settings as well as in the home and community. The Company's initial product offerings were the ReWalk Personal and ReWalk Rehabilitation Exoskeleton devices for individuals with spinal cord injury (collectively, the "SCI Products"). These devices are robotic exoskeletons that are designed for individuals with paraplegia that use the Company's patented tilt-sensor technology and an on-board computer and motion sensors to drive motorized legs that power movement. These SCI Products allow individuals with spinal cord injury the ability to stand and walk again during everyday activities at home or in the community.

The Company has sought to expand its product offerings beyond the SCI Products through internal development and distribution agreements. The Company has developed its ReStore Exo-Suit device ("ReStore"), a powered, lightweight soft exo-suit intended for use during the rehabilitation of individuals with lower limb disabilities due to stroke. The Company is no longer actively commercializing the ReStore product. The Company distributes the MYOLYN MyoCycle FES Pro cycles to U.S. rehabilitation clinics and the MyoCycle Home cycles available to U.S. veterans through VA hospitals on a non-exclusive basis.

Following the acquisition of AlterG, Inc. by Lifeward in August 2023, the Company added the AlterG Anti-Gravity Treadmill to its portfolio of rehabilitation and recovery solutions. The Anti-Gravity Treadmill utilizes differential air pressure technology to reduce body weight impact during walking and running therapy and is used in rehabilitation clinics, sports performance facilities and hospitals worldwide. Fiscal year 2025 is the first reporting period in which the Anti-Gravity Treadmill product line is included in the Company's Conflict Minerals disclosure.

Our products are marketed and sold worldwide, with principal markets in the United States and Europe.

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
Adopt, communicate and commit to a supply chain policy for minerals from conflict-affected and high-risk areas.

We have continued to communicate our Conflict Minerals Policy (the "Policy") related to our sourcing of 3TG to our suppliers and other stakeholders. Our Policy outlines our commitment to responsible sourcing and the requirements imposed on participants in our supply chain and is available on the "Charters & Policies" under the "Corporate Governance" page in the "Investor Relations" section of our website at https://ir.golifeward.com/corporate-governance/charters-and-policies. 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.

Structure internal management systems to support supply chain due diligence.

A cross-functional Conflict Minerals steering committee operates our Conflict Minerals program. The committee consists of representatives from the Company's finance and purchasing functions and is led by our Principal Financial Officer. Regular meetings of our Conflict Minerals steering committee were held, and the committee updated representatives of our senior management on the status of the Conflict Minerals program.

Establish a System of Controls and Transparency over the Conflict Minerals Supply Chain.

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. We have also adopted a process to maintain business records relating to 3TG due diligence, including retention of records of our due diligence processes, findings and resulting decisions for a period of five years.

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.

Establish a Company-level Grievance Mechanism.
Our Policy includes a grievance procedure by which employees, suppliers and other stakeholders may contact us should they wish to seek guidance or report concerns regarding Conflict Minerals. Concerns or grievances reported through this procedure are reviewed by the relevant staff members and follow-up activities are conducted, as appropriate.
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 80 relevant suppliers whose products may contain 3TG.
Request Conflict Minerals Reporting Templates (CMRTs) from suppliers.

We surveyed 80 suppliers, through our third-party service provider, 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 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 37 out of 80 suppliers (46%).

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" or "active" smelter or refiner list, which lists all facilities that have received a RMAP "conformant" or "active" 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, through our third-party service provider, in an effort to secure revised 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 are working to improve our due diligence processes with respect to 3TG. Our risk mitigation efforts during 2025 included those discussed in this section.
Participate in Existing Industry Conflict Minerals Initiatives.
In light of the complexity of our and our suppliers' supply chains, we are currently unable to assess adequately all of the risks in our supply chain. However, we continue to engage with suppliers to obtain current, accurate and complete information about our supply chain through the use of version 6.5, or higher, of the CMRT and to improve due diligence efforts to ensure responsible sourcing in compliance with our Policy.

Report Findings to Designated Senior Management.
Our senior management, including our Chief Executive Officer, is briefed about our supply chain due diligence efforts, risk analysis results and mitigation efforts.

Devise, Adopt and Implement a Risk Management Plan and Monitor Risk Mitigation Efforts.

Our Policy seeks to encourage suppliers to responsibly source Conflict Minerals, but does not necessarily seek to eliminate sourcing from any of the Covered Countries. We also periodically review our progress, assess identified risks and determine follow-up action, as follows:

We follow up on inconsistent, incomplete, or inaccurate responses, and send reminders to suppliers who have not responded to our requests for information, through our third-party service provider.

Suppliers that source from smelters or refiners from any of the Covered Countries, where such smelters or refiners are not certified by the RMAP, are contacted and are asked to submit more information about their sourcing practices, including a corrective action plan.
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 https://ir.golifeward.com/corporate-governance/charters-and-policies. 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.

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 80 identified suppliers were surveyed using version 6.5, or higher, of the CMRT. We received survey responses from 46% of our suppliers. The results of the survey do not allow us 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.

Facilities Used to Process the Conflict Minerals in the Covered Products

Based on the information obtained during the minerals supply chain due diligence process, we were unable to conclusively determine the origin or likely origin of all the Conflict Minerals contained in the Covered Products. Based on the information provided by our suppliers as well as by the RMI, as of the date of this CMR, we believe that the facilities that may have been used to process the Conflict Minerals in our products during the reporting period in the 2025 calendar year may include the smelters or refiners listed in Annex I hereto.

Countries of Origin of the Conflict Minerals in the Covered Products

Based on information provided by our suppliers and the RMI, the Conflict Minerals contained in our Covered Products may have originated from one or more of the countries identified in Annex II hereto.

We can only provide reasonable, not absolute, assurance regarding the source and chain of custody of the Conflict Minerals in our Covered Products, since the information comes from direct and secondary suppliers and the RMI. Information gathered from our suppliers is not on a continuous, real-time basis. Despite our efforts to follow up with certain suppliers, we did not receive responses from all suppliers, and the suppliers who responded showed varying degrees of cooperation with our inquiries.

Part IV. Implementation of Strategies to Respond to Identified Risks and Future Steps

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 ensure 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.
Continuing to implement the Company's Conflict Minerals Policy.

5.
Engaging with suppliers to encourage them to provide requested information for future reporting years.

6.
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.

7.
Using revised and updated versions of the CMRT for our survey tools.

Lifeward Ltd. published this content on May 29, 2026, and is solely responsible for the information contained herein. Distributed via EDGAR on May 29, 2026 at 20:06 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]