It doesn’t look so to me.
First, it seems to have a small metallized ring at the front that I can’t explain otherwise than “it directs light towards the main reflector”.
Second - it’s just too flat and angles don’t seem to add up. I think it would generate extremely wide beam with light hitting the side reflector directly. And we know that it actually collimates fine. Not neearly as well as a TIR in Olight S1 Mini but the output is nevertheless quite throwy.