1. Introduction

Modern slavery is the illegal exploitation of people for personal or commercial gain. It takes various forms, such as slavery, servitude, forced and compulsory labour, debt bondage and human trafficking, often in horrendous conditions from which the victim cannot escape. All of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Businesses have a key part to play in the effort to tackle this crime and protect vulnerable workers from exploitation. Moon Surgical SAS have a zero tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chains.

Section 54 of the UK Modern Slavery Act (2015) requires commercial organisations that operate in the UK and have an annual turnover above £36m to produce a Slavery and Human Trafficking statement each year.

2. Statement

We do not have an annual turnover above £36m, so therefore are not required under this legislation to produce a yearly statement. However, we choose to voluntarily produce a statement.

This statement relates to the company financial year ending 31st December 2025.

The Modern Slavery Act specifically states that any statement must include ‘the steps the organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains, and in any part of its own business’.

We cannot guarantee that the entire supply chain is slavery free, and this is not a requirement, but we will demonstrate the steps we have taken to assess risk and mitigate those.

3. Organisational Information

Moon Surgical is a medical equipment manufacturer that operates out of dual headquarters in Paris, France, and San Carlos, California. Founded in 2019, the organisation employs a global workforce of specialized professionals across robotics engineering, machine learning, and clinical operations to act as a co-operative robotic surgical assistant.

4. Our Supply Chain and Procurement

Moon Surgical SAS operates a global supply chain, primarily based in the United States and Europe.

Moon Surgical SAS are committed to ensuring transparency in our own business and our supply chains and expect the same due diligence and commitment from our suppliers, contractors and business partners.

When procuring goods or services we have processes in place to consider Modern Slavery risks. We ensure we carry out supplier due diligence. This can include:

• Robust supplier selection and policies
• Supplier questionnaire and audit
• Mapping of the supply chain to identify geographical areas of higher risk

5. Areas of Risk Identified Within the Business and Supply Chain

Supplier risk assessment

We conduct an annual risk assessment of our suppliers in relation to Modern Slavery using the following process:

• The risk level is determined using the scale according to the Global Slavery Index.
• This is cross referenced with the list of goods from the US Department of Labor that have been identified to be at higher risk of being produced by child or forced labour.
• Then the sector is checked against the ILO’s Global Estimates of Modern Slavery.

Findings

Tier 1

We mapped 219 Tier 1 suppliers, with 98% being classified as low risk. The remaining 2% were classified as medium or high risk due to the country of origin and goods and industry markers.

The nature of the organisational structure means that the risk within the business and supply chain for Tier 1 is identified as Low.

This risk level will be reviewed yearly and reported on.

Tier 2

We have not mapped our Tier 2 suppliers.

6. Policies and Processes Relating to Modern Slavery

The following company policies support our Modern Slavery due diligence:

• Ethical Trading, Human Rights and Labour Standards Policy
• Code of Conduct
• Supplier Code of Conduct

KPIs

We will use key performance indicators (KPIs) to measure how effective our actions to identify and address modern slavery practices in any part of our operations and supply chains have been.

Below are the key performance areas that we assess:

1. Policies
2. Risk Assessments
3. Due Diligence
4. Training

Against each of these focus areas we have developed KPIs that are used to assess the effectiveness of our actions. These include:

1. Update of the Modern Slavery Statement and review of supporting policies annually
2. Annual Supplier modern slavery risk assessment
3. The number of modern slavery cases identified and remediated
4. Policy updates received by employees

Over subsequent reporting periods, we will continue to review and enhance these KPIs and develop further metrics to assess the effectiveness of our actions, in line with continuous improvement.

7. Training of Employees Around Modern Slavery

Training on Modern Slavery is provided through policy updates to all employees.

8. Reporting

If a case of Modern Slavery is suspected, then the following is advised.

A suspected victim of modern slavery is not to be confronted directly as this may endanger them.

If there is an immediate risk to life, call the local emergency number (e.g. 911 in the US, 112 in Europe, 999 in the UK), then contact the national helpline or report it online.

Helplines and Online Reporting

Employees are required to take their suspicions to their line manager and also have access to a whistleblowing process.

If there are concerns around modern slavery with any of our suppliers, we will first look to work with them to remedy the situation with an improvement action plan implemented and more rigorous auditing of the organisation.

If the response from any of our suppliers seems inadequate and appropriate measures are not put in place to address coercion, threat, abuse, and exploitation of workers, then we would look to give that company more support, guidance and incentives to tackle the issue. This could include working with at-risk suppliers to provide training, messages and business incentives or guidance to implement anti-slavery policies.

If modern slavery is identified or suspected, and resolution is not possible with the supplier, then we will engage with local Non-Governmental Organisations, industry bodies, trade unions or other support organisations to attempt to remedy the situation. If warranted, we will contact local government and law enforcement bodies. Our approach will always consider the safest outcome for the potential victims while also remembering the economic influence and control which the organisation holds over those who may be committing these crimes.

9. Breaches

Any employee who is in breach of our policies related to this statement will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

Any suppliers, individuals or organisations working with us, or on our behalf, who breach our policies related to this statement may have their relationship or contract with us terminated.

10. Responsibility

Anne Osdoit, CEO, has overall responsibility for this statement.

11. Review and Communication

This statement will be reviewed by senior management, signed by a director or equivalent and then published on our website. Internally it will be sent to all employees and made available online to our supply chain and other interested stakeholders.

12. Board / Senior Management Approval

Signed: Anne Osdoit
Job title: CEO
Date: 30th June 2026