Key Findings
- Economic: SEC subsidiary exhibits repeatedly identify Globus Medical Israel Ltd/Limited as a controlled Israeli subsidiary from 2012 through 2021, establishing a sustained historical Israeli economic nexus. The audited record does not establish the office, workforce, Israeli revenue, tax payments, manufacturing, R&D or investment characteristics required for a higher operational-presence score.1, 2, 3, 4
- Political: The historical Israeli subsidiary supports an incidental Israel nexus, but no public evidence identified of Israel-facing advocacy, lobbying, political donations, military mobilization, settlement activity, suppression of Palestinian advocacy or another qualifying political result.4, 5
- Corporate structure: NuVasive became wholly owned by Globus in September 2023 and Nevro in April 2025. Reviewed subsidiary disclosures did not identify an Israeli operating company within either acquired group.6, 7, 8
- Not found: No public evidence identified of verified IDF/Israeli Ministry of Defense contracting, Israeli military deployment, settlement operations, Israeli state surveillance or digital-weapons provision. Globus’s documented technology is principally civilian medical technology, including surgical robotics and navigation.9, 10, 11
Target Profile
| Field | Detail |
|---|---|
| Company Name | Globus Medical, Inc.12 |
| Jurisdiction | Delaware, United States.12 |
| Headquarters | 2560 General Armistead Avenue, Audubon, Pennsylvania.12 |
| Sector | Musculoskeletal medical technology and healthcare solutions, including spine, orthopedic trauma, joint reconstruction, biologics and enabling technologies.12, 13 |
| Ownership | Public company listed on the NYSE as GMED. The 2026 proxy reports founder and Executive Chairman David C. Paul with 66.2% combined voting power; BlackRock and Janus Henderson were each reported below 10% of Class A shares.14 |
| Key Executives / Governance | David C. Paul, founder and Executive Chairman; Keith W. Pfeil, President and Chief Executive Officer since July 2025. Director Daniel T. Lemaitre previously served in executive roles at Israel-based BlueWind Medical.14, 15 |
| Israeli-Nexus Summary | SEC filings document a controlled Israeli subsidiary repeatedly from 2012 through 2021; its present legal and operational status remains unresolved, and the audits did not establish a current Israeli office, military relationship, settlement operation or qualifying political/digital result.1, 4, 16 |
Key Facts:
- Globus was founded in 2003 and is headquartered in Pennsylvania.17
- NuVasive became wholly owned by Globus on 1 September 2023.6
- Nevro became wholly owned by Globus on 3 April 2025.7
- Globus’s 2025 significant-subsidiary exhibit names NuVasive and Nevro entities but no Israeli subsidiary; the exhibit expressly omits subsidiaries that are not significant in the aggregate, so omission is not proof that every Israeli legal or commercial presence has ceased.16
- Current legal status, address and any claimed dissolution of the historical Globus Medical Israel entity remain unresolved because the registry-mirror lead used during research could not be independently retrieved.
Executive Summary
Globus Medical is a U.S. musculoskeletal medical-technology group whose strongest documented Israel nexus is historical corporate ownership. SEC subsidiary exhibits list Globus Medical Israel Ltd/Limited in 2012, 2015, 2018 and 2021, establishing that Globus directly controlled an Israeli corporate entity over a multi-year period.1, 2, 3, 4 That evidence supports a real economic relationship with Israel, but the audited record does not establish the subsidiary’s workforce, physical office, Israeli revenue, taxes, manufacturing, R&D activity, investment scale or profit flows. The current status of the Israeli entity remains unresolved.
The group’s subsequent acquisitions do not materially strengthen the documented Israel nexus. NuVasive became wholly owned by Globus in September 2023, while Nevro became wholly owned in April 2025.6, 7 NuVasive’s 2022 significant-subsidiary exhibit did not identify an Israeli subsidiary, and Nevro’s final standalone subsidiary exhibit identified entities in Switzerland, the United Kingdom, Australia, Germany, Costa Rica and the United States without listing Israel.8, 18 No public evidence identified that either acquisition brought a named Israeli manufacturing, R&D or operating subsidiary into Globus.
The military and digital audits found no qualifying result. No public evidence identified of a verified Globus, NuVasive or Nevro contract with the Israeli Ministry of Defense, IDF, Israel Prison Service, Border Police or Israeli intelligence services; military deployment; supply to Israeli defence primes; weapons or munitions activity; settlement infrastructure work; or military logistics.12, 13 Likewise, no public evidence identified of Globus providing Israeli state bodies with surveillance, biometrics, offensive cyber, targeting AI, autonomous weapons support or sovereign-cloud services. The company’s verified advanced digital products are surgical technologies such as ExcelsiusGPS and ExcelsiusHub, described for clinical robotic navigation, trajectory guidance, imaging registration and operating-room workflows.10, 11
The political audit similarly found no qualifying downstream political result. No public evidence identified of Globus statements supporting Israeli military policy or settlements, Israel-related lobbying, anti-BDS advocacy, corporate donations to Israeli military or settlement bodies, crisis mobilization for Israeli forces, suppression of Palestinian advocacy, settlement activity or a non-commercial Israeli state partnership.5, 19 The historical Israeli subsidiary therefore establishes economic integration but does not by itself prove political advocacy, military support or occupation-related conduct.
Under the fixed, human-vetted Complicity Index V6.5 scoring, the economic domain is consequently the only domain with a non-zero V score: Economic 2.17. Military and Digital score 0.00, while Political has an examiner-adjudicated incidental Impact score of 2.00 but zero Magnitude and Proximity, producing a Political score of 0.00. The resulting BRS is 181, Tier E (Minimal/No Complicity).
Timeline of Relevant Events
| Date | Event |
|---|---|
| 2003 | Globus Medical was founded; its filings identify it as a Delaware corporation headquartered in Pennsylvania.17 |
| 2012 | SEC subsidiary disclosure lists Globus Medical Israel Ltd in Israel.1 |
| 2015 | SEC subsidiary disclosure again lists the Israeli subsidiary.2 |
| 2018 | SEC subsidiary disclosure lists Globus Medical Israel Limited.3 |
| 31 Dec 2021 | The Israeli entity remained listed in Globus’s subsidiary exhibit.4 |
| 1 Sep 2023 | NuVasive became a wholly owned Globus subsidiary through completion of the merger.6 |
| 3 Apr 2025 | Globus completed its acquisition of Nevro, making Nevro wholly owned.7 |
| 31 Dec 2025 | Globus’s significant-subsidiary exhibit names NuVasive and Nevro entities but no Israel entity; the exhibit states that non-significant subsidiaries may be omitted.16 |
| 2026 | Current Globus office/contact materials reviewed in the audits did not identify an Israel office.20 |
Corporate Overview
Globus Medical, Inc. is a Delaware-incorporated public medical-technology company headquartered in Audubon, Pennsylvania and listed on the NYSE as GMED.12 Its disclosed business is the development and commercialization of musculoskeletal healthcare technologies, including implants, biologics, orthopedic trauma and joint-reconstruction products, imaging, navigation and robotic surgical systems.12, 13
The historical Israeli relationship is directly documented through Globus’s own SEC subsidiary exhibits. Those filings identify Globus Medical Israel Ltd/Limited in 2012, 2015, 2018 and 2021.1, 2, 3, 4 This is stronger evidence than a distributor lead or indirect association because it establishes corporate control of an Israeli legal entity at those dates.
The audits could not verify the entity’s present legal status. A registry-mirror lead contained possible company-number, address and dissolution information, but the page could not be independently retrieved, so those details were excluded from the verified record. The 2025 significant-subsidiary exhibit does not name an Israeli entity, and Globus’s current office/contact page reviewed by the auditors does not list an Israel office.16, 20 Neither point conclusively proves complete withdrawal because the SEC exhibit expressly omits subsidiaries that are not significant in the aggregate.
Globus’s acquired groups were separately checked. NuVasive became wholly owned in September 2023, but its 2022 significant-subsidiary disclosure did not name an Israeli entity.6, 18 Nevro became wholly owned in April 2025; its pre-acquisition subsidiary exhibit likewise listed several foreign jurisdictions without Israel.7, 8 No public evidence identified of a current NuVasive or Nevro Israeli R&D centre, controlled Israeli operating company or manufacturing site.
The governance review also identified a personal professional connection rather than a Globus corporate transaction: director Daniel T. Lemaitre served as executive chairman and later CEO of Israel-based BlueWind Medical, including service as CEO from January 2020 to September 2024.15 No public evidence identified that Globus acquired, controlled, invested in or procured from BlueWind Medical, and the audits did not treat Lemaitre’s role as evidence of military or political activity by Globus.
Domain Summaries
Military: Military
Mechanism of Involvement
No qualifying military mechanism was established. Globus’s historical Israeli subsidiary demonstrates commercial corporate presence, but the military audit found no public evidence identified of a verified Globus, NuVasive or Nevro contract, tender award, framework agreement or memorandum with the Israeli Ministry of Defense, IDF, Israel Prison Service or Border Police.
Globus describes its products as medical technologies for musculoskeletal care. Its Excelsius platforms involve surgical robotics and navigation, while its broader business includes implants, imaging, biologics and orthopedic technologies.10, 12, 13 Nevro’s HFX/Senza products are described as spinal-cord-stimulation systems for chronic pain.21 No public evidence identified of ruggedised, tactical or defence-grade Israeli variants, Israeli military end-user certificates, arms export licensing, weapons systems, munitions, targeting systems or military-specific product development.
No public evidence identified of Globus, NuVasive or Nevro supplying components or specialist services to Elbit Systems, Israel Aerospace Industries, Rafael or IMI/Elbit Land; providing military-base logistics; or participating in construction, maintenance or demolition of settlements, checkpoints, barriers, detention facilities or military infrastructure.
Counter-Arguments and Evidence Limits
The strongest defence is that the verified product record is civilian and clinical. The audits establish a medical-technology business and do not establish Israeli military procurement or deployment.12, 13 A civilian medical device could theoretically be bought or used by a military healthcare system, but no such Israeli procurement was verified.
A possible Sheba Medical Center lead surfaced during research, but its underlying registry-mirror source could not be independently retrieved and no primary procurement record was found. It therefore remains unresolved and cannot establish a paid state contract, military purchaser or military deployment.
Civil-society searches against several settlement and corporate-accountability sources did not return a responsive Globus-specific military result within the bounded research pass. Those negative searches are not proof against every historic or non-indexed record.
Named Entities and Evidence Map
- Globus Medical, Inc. - civilian musculoskeletal medical-technology parent.12
- Globus Medical Israel Ltd/Limited - historically controlled Israeli subsidiary documented through 2021; no verified military role.1, 4
- NuVasive - controlled by Globus from September 2023; no public evidence identified of Israeli military procurement.6
- Nevro - controlled by Globus from April 2025; no public evidence identified of an Israeli military/security end user.7, 21
- Sheba Medical Center lead - unresolved; no primary procurement evidence established.
- Military result - I=0.00, M=0.00, P=0.00; V=0.00.
Digital: Digital
Mechanism of Involvement
No mechanically eligible digital frame was established. Globus’s verified digital technologies are principally medical enabling systems. ExcelsiusGPS is described as a robotic navigation platform that uses medical imaging and provides real-time trajectory guidance and visualization during surgical procedures.10 ExcelsiusHub provides freehand navigation, imaging registration and patient-array monitoring in surgical workflows.11
No public evidence identified that Globus provided facial recognition, identity biometrics, predictive policing, social-media surveillance, sentiment analysis or workforce-surveillance systems to Israeli authorities. No public evidence identified of Globus supplying AI or computer-vision systems to Israeli state, military or security bodies for targeting, autonomous weapons, threat detection or intelligence exploitation.
The audit also found no public evidence identified of participation in Project Nimbus, an Israel-specific sovereign-cloud programme, an Israeli data centre, or an Israeli state-data hosting/residency service. Globus’s 2026 privacy notice names Google Analytics and Hotjar in its website context but does not identify Israel as a hosting or processing jurisdiction or disclose an Israeli-origin enterprise-security relationship.22
Counter-Arguments and Evidence Limits
The principal counter-argument is functional: technologies such as robotic guidance, imaging and computer-assisted navigation can be digitally sophisticated without being surveillance or military technology. The retrieved Globus materials place these systems in clinical surgical care.10, 11
No public evidence identified of a Globus relationship with Check Point, Wiz, SentinelOne, CyberArk, NICE, Verint, Claroty or another Israeli-origin enterprise-technology supplier in the bounded research. This should not be read as proof that no ordinary commercial software relationship could exist; it means no verified relationship supporting the Digital mechanism was established.
A separate cybersecurity-incident lead could not be independently retrieved. Its details and any claimed geographic attribution remain unresolved and were excluded from scoring.
Named Entities and Evidence Map
- ExcelsiusGPS - robotic surgical-navigation platform; no verified Israeli security deployment.10
- ExcelsiusHub - freehand surgical-navigation and imaging-registration system; no verified surveillance or military deployment.11
- Globus Medical Israel Ltd/Limited - historic commercial subsidiary; its existence does not establish a digital-security result.1, 4
- BlueWind Medical - Israel-based medical-device company formerly led by Globus director Daniel T. Lemaitre; no public evidence identified of Globus ownership, procurement or control.15
- Digital result - I=0.00, M=0.00, P=0.00; V=0.00.
Economic: Economic
Mechanism of Involvement
The economic domain contains the dossier’s strongest documented nexus. Globus’s own SEC subsidiary exhibits identify a directly controlled Israeli corporate entity repeatedly across 2012, 2015, 2018 and 2021.1, 2, 3, 4 The examiner therefore treated the relationship as a real, sustained Israeli economic nexus rather than a one-off association.
The evidence does not establish the characteristics necessary for a higher operational-presence band. No reliable current Israel workforce figure, office footprint, local revenue, Israeli tax contribution, manufacturing operation, R&D centre, capital-investment figure, profit flow or Israel-specific market share was identified. No public evidence identified of Israeli beneficial control of Globus; the 2026 proxy instead reports David C. Paul with 66.2% combined voting power.14
No public evidence identified of settlement-origin manufacturing or sourcing, settlement labeling violations, settlement infrastructure activity, Israeli sovereign-bond holdings or Israeli state ownership. No Israel-specific revenue or profit-repatriation figure was identified in the reviewed filings.
The fixed examiner adjudication accordingly places both Impact and Magnitude at the upper end of the low band, while Proximity is materially higher because the subsidiary relationship was one of direct corporate control rather than an indirect vendor or shareholder association.
Counter-Arguments and Evidence Limits
The strongest defence is temporal and evidentiary. The subsidiary is historically documented, but its present status is unresolved. Globus’s 2025 significant-subsidiary list does not name Israel, and the current office list reviewed in 2026 did not identify an Israel office.16, 20 Because the SEC exhibit may omit subsidiaries that are not significant, these facts cannot establish definitive exit.
The audit also found no evidence quantifying the Israeli subsidiary’s operating scale. There is no verified current headcount, revenue, manufacturing, R&D, tax or investment figure. This limitation is why the examiner reduced Impact to 3.9, below the V6.5 operational-presence band that would require stronger evidence of substantive physical or economic operations.
The NuVasive and Nevro acquisitions do not supply a stronger Israel nexus on the audited record. Their reviewed subsidiary exhibits did not name Israeli entities.8, 18
Named Entities and Evidence Map
- Globus Medical Israel Ltd/Limited - directly controlled Israeli subsidiary documented across multiple SEC filings through 2021.1, 2, 3, 4
- Globus Medical, Inc. - controlling U.S. parent.
- NuVasive - wholly owned from September 2023; reviewed pre-merger disclosure did not identify an Israeli subsidiary.6, 18
- Nevro - wholly owned from April 2025; pre-acquisition subsidiary disclosure did not identify an Israeli subsidiary.7, 8
- David C. Paul - founder and dominant voting holder; no public evidence identified of Israeli beneficial control of Globus.14
- Economic result - I=3.90, M=3.90, P=7.20; V=2.17.
Political: Political
Mechanism of Involvement
The political audit establishes an incidental Israel connection through the historical subsidiary but no qualifying political outcome. No public evidence identified of an official Globus position supporting Israeli military operations, settlement expansion, anti-BDS legislation or another Israel-Palestine political programme.
No public evidence identified of Globus, NuVasive or Nevro lobbying on Israel-Palestine policy; making corporate donations to the IDF, FIDF, JNF/KKL, Israeli reservist funds or settlement organizations; providing corporate assets to an Israeli conflict effort after 7 October 2023; or participating in a state-backed Israeli branding or political initiative.
No public evidence identified of settlement offices, service locations, contracts or equipment deployments in the occupied West Bank, East Jerusalem or occupied Golan Heights. No public evidence identified of Globus disciplining employees for Palestine-related expression or operating a platform that suppressed Palestine-related content.
The examiner therefore retained an Impact score of 2.00, reflecting the incidental audited Israel nexus, but assigned Magnitude 0.00 and Proximity 0.00 because the record did not establish a V6.5-eligible downstream political result.
This is the V6.5 Impact-only neutrality floor triggered by the positive economic-domain result; it does not assign Magnitude or Proximity to an unevidenced political act.
Counter-Arguments and Evidence Limits
The company’s strongest defence is that ordinary commercial presence in Israel is not itself evidence of political advocacy or support for government policy. The audits deliberately separate the historical subsidiary from military, settlement and political conclusions.
No public evidence identified of Globus senior leaders publishing Israel-Palestine advocacy, serving in the Israel-focused political organizations checked, or personally financing the military or settlement bodies searched. David C. Paul’s official biography instead describes a medical-device and academic engineering career.15
Targeted civil-society and settlement-database searches did not surface a substantive Globus-specific result within the bounded search. Those checks do not establish exhaustive absence, but no verified contrary evidence was available for scoring.
Named Entities and Evidence Map
- Globus Medical Israel Ltd/Limited - establishes historical economic integration, not a demonstrated political result.1, 4
- David C. Paul - founder and Executive Chairman; no public evidence identified of qualifying Israel-Palestine advocacy in the audited record.14, 15
- Keith W. Pfeil - President and CEO since July 2025; no public evidence identified of qualifying Israel-Palestine advocacy.14
- Daniel T. Lemaitre - former BlueWind Medical executive; the audited connection is civilian medical-sector experience and does not establish political activity by Globus.15
- Political result - I=2.00, M=0.00, P=0.00; V=0.00.
Complicity Index Score
Method: V6.5
| Domain | I | M | P | V-Domain Score |
|---|---|---|---|---|
| Military | 0.00 | 0.00 | 0.00 | 0.00 |
| Digital | 0.00 | 0.00 | 0.00 | 0.00 |
| Economic | 3.90 | 3.90 | 7.20 | 2.17 |
| Political | 2.00 | 0.00 | 0.00 | 0.00 |
- V_MAX: 2.17 Avg_OTHERS: 0.00
- BRS Score: 181 Tier: E (Minimal/No Complicity)
V_MAX is driven entirely by Economic: direct historical control of an Israeli subsidiary supports a sustained economic nexus, while the absence of verified scale indicators limits Impact and Magnitude. Military and Digital have no qualifying result, and Political’s incidental Impact does not produce a domain score because its Magnitude and Proximity are zero.
The V6.5 method is scale-free and evidence-only: Impact classifies the activity type, Magnitude reflects its demonstrated scale, and Proximity reflects directness. These scores are the fixed, human-vetted values after examiner adjudication and deterministic QA.
Methodology Note
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Evidence is restricted to the four completed domain audits and their cited sources. Unsupported allegations, inaccessible leads and unresolved registry claims are not promoted into findings.
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V6.5 is scale-free: Impact (I) measures the nature of the documented activity, Magnitude (M) its demonstrated scale, and Proximity (P) its directness to the relevant nexus.
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Temporal status matters. Historical, divested or apparently exited operations are distinguished from verified current activity, and present status is left unresolved where the evidence does not support a firm conclusion.
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Entity attribution is bounded. Conduct by an acquired company is attributable only from the documented control date, and personal, supplier or portfolio relationships do not create transitive guilt for the parent without evidence of a relevant corporate mechanism.
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Settlement operation, where verified, can support both Economic and Political because it constitutes economic operation and a politically relevant territorial result. No such Globus settlement operation was verified here.
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“No public evidence identified” is used where the bounded checks found no qualifying evidence. It records the audit result rather than asserting universal or permanent absence.
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Specific research limits remain: the MIL action limit was reached before separate PAX, Al-Haq, BankTrack and Don’t Buy Into Occupation checks; the requested A/HRC/59/23 report was not checked line by line; an official Israeli registry record was not retrieved; and the OHCHR PDF and registry-mirror/Sheba leads did not pass independent retrieval. These are unresolved checks and access limits, not evidence of clearance or absence.
Footnotes
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https://www.sec.gov/Archives/edgar/data/1237831/000119312512331390/d319036dex211.htm ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10
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https://www.sec.gov/Archives/edgar/data/1237831/000123783116000075/gmed123115ex211.htm ↩ ↩2 ↩3 ↩4 ↩5 ↩6
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https://www.sec.gov/Archives/edgar/data/1237831/000123783119000014/gmed123118ex211entities.htm ↩ ↩2 ↩3 ↩4 ↩5 ↩6
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https://www.sec.gov/Archives/edgar/data/1237831/000156276222000037/gmed-20211231xex21_1.htm ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11
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https://www.sec.gov/Archives/edgar/data/1237831/000162828026011209/gmed-20251231.htm ↩ ↩2
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https://www.sec.gov/Archives/edgar/data/1142596/000119312523227202/d469541d8k.htm ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7
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https://www.sec.gov/Archives/edgar/data/1237831/000119312525071923/d931031d8k.htm ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7
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https://www.sec.gov/Archives/edgar/data/1444380/000144438025000024/nvroex21_1.htm ↩ ↩2 ↩3 ↩4 ↩5
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https://www.globusmedical.com/musculoskeletal-solutions/excelsiustechnology/excelsiusgps/ ↩ ↩2 ↩3 ↩4 ↩5 ↩6
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https://www.globusmedical.com/musculoskeletal-solutions/excelsiustechnology/excelsiushub/ ↩ ↩2 ↩3 ↩4 ↩5
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https://www.sec.gov/Archives/edgar/data/1237831/000162828026011209/gmed-20251231.htm ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10
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https://www.globusmedical.com/international/solutions/ ↩ ↩2 ↩3 ↩4 ↩5
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https://www.sec.gov/Archives/edgar/data/1237831/000162828026027196/gmed-20260424.htm ↩ ↩2 ↩3 ↩4 ↩5 ↩6
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https://www.globusmedical.com/about/board-of-directors/ ↩ ↩2 ↩3 ↩4 ↩5 ↩6
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https://www.sec.gov/Archives/edgar/data/1237831/000162828026011209/gmed-20251231xexx211.htm ↩ ↩2 ↩3 ↩4 ↩5
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https://www.sec.gov/Archives/edgar/data/1237831/000156276225000026/gmed-20241231x10k.htm ↩ ↩2
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https://www.sec.gov/Archives/edgar/data/1142596/000114259623000013/nuva-20221231xexx211.htm ↩ ↩2 ↩3 ↩4
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https://www.sec.gov/Archives/edgar/data/1237831/000156276224000032/gmed-20231231x10k.htm ↩
