Modern Slavery and Human Trafficking Statement 2026

Publication Information

Publication information

Statement Overview

Statement overview

“We maintain a zero-tolerance approach to modern slavery and human trafficking.”

Introduction

Introduction

AIRS Medical operates in the medical imaging healthcare sector as a provider of certain AI-powered software services. AIRS Medical Europe GmbH., AIRS Medical USA, Inc., and AIRS Medical Japan G.K. form part of the AIRS Medical network or group, whose ultimate parent company is AIRS Medical Inc., headquartered in the Republic of Korea (collectively, “AIRS Medical”, “we”, “our”, or “us”).

This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015 to prevent modern slavery and human trafficking within our business and across our supply chain.

Modern slavery is a crime and a serious violation of fundamental human rights. It can take many forms, including slavery, servitude, forced or compulsory labour, and human trafficking, all of which involve the exploitation of individuals for personal or commercial gain.

As an employer operating through a global network, it remains a priority for AIRS Medical to conduct business ethically, source responsibly, and work to prevent modern slavery and human trafficking throughout our organisation and across our supply and distribution chains. We maintain a zero-tolerance approach to modern slavery and human trafficking and are committed to fostering a respectful, non-discriminatory working environment for our personnel across all of our global offices.

We recognise that different jurisdictions may define or interpret prohibited practices associated with human trafficking and modern slavery in various ways. Therefore, this statement and the related policies and practices of AIRS Medical are intended to be read and applied to the fullest extent permitted by applicable law.

Our Business Practice

Our business practice

Organisation and Supply Chain Structure

Our Business

AIRS Medical is a healthcare technology company that develops AI-powered software designed to improve the quality of medical imaging and analyse data to generate reports that may assist medical professionals in improving clinical efficiency and workflow. Our operations are primarily technology-driven and managed through a hybrid working environment, including both remote-based and office-based arrangements. We do not operate in sectors typically associated with a high risk of modern slavery. While the inherent risk of modern slavery within our direct operations is perceived as low, we recognise that risks may arise through third-party relationships, supply and distribution chains. We therefore take appropriate and proportionate steps, compared to the size, sophistication and complexity of our business operation, to identify and mitigate these risks.

Our Governance

We maintain governance, risk management, and compliance frameworks that support ethical and responsible business practices. These frameworks are designed to promote transparency, accountability, and compliance with applicable laws and regulations in the jurisdictions in which we operate. We expect the same high standards from all of our contractors, suppliers, distributors, and other business partners.

Organisation and Operation

We are generally characterised as a small- to medium-sized enterprise. Our global headquarters is located in Seoul, South Korea, and we operate international regional offices in the United States, Germany, and Japan. More than half of our employees are based in South Korea, with the remainder of our workforce located across the regional offices. We maintain records of our suppliers and distributors involved in the sourcing of equipment and the distribution of our services. We also maintain records relating to the services we provide, the volume of those services, and the sectors in which we operate. Our supply chain is relatively compact and consists predominantly of the procurement of IT systems, including software-as-a-service (SaaS) solutions and computing equipment, as well as office supplies and consumables.

Supply Chain Structure

Our principal products are software services, and the reach of those services is global rather than limited to particular regions or countries. In order to deliver our services, we may source hardware, workstations, and computer equipment from responsible sellers, recognised e-commerce platforms, or contracted suppliers with an established local reputation and an established record of lawful business activity.

Distribution Chain Structure

We work with distributors in countries where we intend to market and distribute our services. Distributors are generally required to disclose how they distribute our services and engage with customers in their local markets. Where a distributor proposes to appoint a third party, we require disclosure of that third party’s identity, status, and role before permitting that party to become part of our distribution chain. We recognise the importance of maintaining oversight of our supply and distribution chains so that we can better understand the risk of modern slavery and take appropriate steps to mitigate that risk.

Commercial Contracts

We do not knowingly enter into business with any organisation that supports, or is found to be involved in, slavery, servitude, forced labour, compulsory labour, or human trafficking. This commitment is reflected in our contractual compliance sections and clauses. Our contractors are bound by compliance clauses requiring them to comply with all applicable laws, regulations, and recognised or accepted industry standards. We do not intend to do business with individuals or entities convicted of offences involving modern slavery or human trafficking, or with those found to have engaged in repeated serious violations of applicable law. Our business partners are expected to ensure that their activities are lawful and do not involve any unauthorised or unlawful practices.

Our Policies

Our policies

Policy Review

We seek to maintain appropriate policies that support our commitment to ensuring that modern slavery and human trafficking do not occur in any part of our business or supply chains. We keep these policies under regular review and update them as necessary.

Internal Operation

Our Anti-Human Trafficking and Anti-Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls designed to prevent slavery and human trafficking in our supply chains. In addition, we have a number of other policies and practices relevant to modern slavery, which are also kept under review on a regular basis. These include: (i) Employee Global Code of Conduct; (ii) Supplier Code of Conduct; (iii) protection of workers’ freedom to terminate employment, prohibition of threats, violence, harassment, and intimidation, prohibition of compulsory overtime, prohibition of child labour, and prohibition of the confiscation of workers’ original identification documents.

Transparency

Unless classified as trade secrets or otherwise treated as confidential, non-public, private or commercially sensitive, our corporate policies are made available to affected persons upon request. We also maintain internal policies and reporting channels intended to make it easy for personnel to raise concerns with management at different levels and to report concerns where necessary.

Communication and Enforcement of Policies

We seek to communicate and enforce our policies throughout the organisation and, where appropriate, among our suppliers, distributors, and subcontractors. This includes communicating our standards and expectations through contractual requirements, internal guidance, and ongoing engagement with relevant stakeholders.

Monitoring and Evaluation

Monitoring and evaluation

Due Diligence and Management

We work with a range of third-party providers, including medical device distributors, technology vendors, professional service firms, and consultants. Our approach to managing modern slavery risk includes: (i) conducting risk-based due diligence on suppliers, business partners, and distributors, proportionate to the nature of the services provided and the size of the relevant business; (ii) giving preference for reputable, well-regulated, duly authorised, approved, and established businesses; (iii) maintaining ongoing oversight of critical suppliers and distributors as part of our broader outsourcing and third-party risk management practices; and (iv) retaining the ability to challenge, remediate, or terminate relationships where ethical or legal concerns are identified, reported, or substantiated, taking into account the seriousness of the issue and the need for prompt action.

Evaluation and Development

As our modern slavery programme is at an early stage, we are in the process of establishing meaningful indicators to assess the effectiveness of the measures we take. As our practices continue to develop, we intend to monitor our progress against the following measures: (i) publication and annual review of this statement, together with the integration of modern slavery and human rights considerations into relevant policies and practices; (ii) development and application of standardised vendor selection and assessment criteria that incorporate labour and human rights considerations; (iii) ongoing monitoring and screening of potential and existing suppliers or distributors where incidents, concerns, or red flags are reported; and (iv) maintenance of designated communication channels for reporting concerns relating to working conditions or human welfare, together with confirmation that any such concerns are reviewed and appropriately addressed.

Responsible Departments

The following departments are involved in the continuing monitoring, review, and development of this statement and of related corporate policies and materials used for monitoring and evaluation: Legal, Human Resources, Quality Assurance (including vendor assessment), and Finance.

Training

Training

Training and Awareness

To promote an appropriate level of understanding of the risks of modern slavery and human trafficking within our business and across our supply and distribution chains, we provide regular training to our staff. These programmes reinforce a culture of dignity, fair treatment, and respect for workers’ rights, which underpins our broader commitment to preventing modern slavery.

Training Materials

We use a variety of materials in our training and awareness programmes, including short videos created for internal organisational training. Upon completion of the training, participants are required to complete quizzes or short-form assessments, and certificates are issued where the required score is achieved. These certificates are retained as part of our compliance records.

Further Steps

Further steps

Future Progress

As our business continues to grow, we intend to strengthen our approach to modern slavery risk on an ongoing basis. We plan to further formalise the documentation of our modern slavery policies and practices and to incorporate labour and human rights considerations more systematically into our management of suppliers and distributors. In order to minimise risk within our commercial network, we may also implement standardised due diligence, onboarding, and monitoring procedures for relevant third parties.

Conclusion

Conclusion

Headway

Compliance with the modern slavery laws and similar laws and regulations in other jurisdictions is an ongoing commitment. As a responsible organisation, we continue to develop and strengthen the way we work to ensure that risks of modern slavery are effectively identified and managed throughout our operations and across our supply and distribution chains. We intend to continue engaging with key suppliers and distributors to improve awareness of modern slavery risks, review relevant policies, and explore opportunities for collaboration in combating modern slavery and human trafficking.

To maintain transparency and open dialogue with other stakeholders, this modern slavery and human trafficking statement is published on AIRS Medical’s website. This enables employees, customers, suppliers, distributors, and other interested parties to review the statement and raise concerns directly with us. We are committed to working only with parties that take their legal and ethical obligations seriously.