ThetaRay Inc. and its affiliates (the “Company”) hold a zero-tolerance approach to modern slavery. The Company is committed to act in transparency, and implement working methods to prevent modern slavery and human trafficking incidents involving the Company, its suppliers, contractors or business partners. This Anti-Slavery policy (the “Policy”) applies to all individuals and entities providing services or engaging with the Company, including its consultants, contractors, suppliers, and other business partners.

1. The aim of the Policy is to help the Company act in accordance with the Modern Slavery Act 2015 and maintain the highest possible standards of business practice. This Policy reflects the Company’s commitment to acting ethically and with integrity in all its business relationships, as well as implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place within its organization and supply chains.

2. Modern slavery is a violation of an individual’s human rights. It includes slavery, forced and compulsory labor, and human trafficking whereby individuals are deprived of their freedom and are exploited for commercial or personal gain as enacted in the Modern Slavery Act, 2015 (“the Act”). The prevention, detection, and reporting of modern slavery in any part of its business or supply chains is the responsibility of all those working for the Company.

3. The Policy shall apply to all the Company’s sites and employees, regardless of such employee's employment agreement or rank, as well as to any contractors, consultants or other persons acting under or on behalf of the Company. The Policy’s values ​​are to be implemented by the Company’s top management and all employees.

4. The Company is committed to helping its employees understand the risks and consequences of slavery and human trafficking and their role in preventing these abuses. The Company will communicate the Policy, making it readily available to employees, contractors, suppliers and customers and will publish the Policy on the Company’s website. The Company is committed to continuously improve its anti-slavery efforts through regular review, evaluation, and enhancement of its policies, procedures, and practices. This policy may be revised as necessary to reflect changes in laws, regulations, or business practices.

5. The Company prohibits the use of forced labor, modern slavery, and human trafficking in all aspects of its business operations and supply chains and takes its responsibilities to combat modern slavery seriously, as demonstrated by the following measures:

• The prevention, detection, and reporting of modern slavery in any part of its business or supply chains is the responsibility of all those working for the Company or under its control.
• All employees are expected to familiarize themselves with the Anti-slavery policy, report any concerns related to slavery or human trafficking, and cooperate with any investigations.
• The Company conducts regular risk assessments and due diligence to assess and monitor the risk of modern slavery and human trafficking within its operations and supply chains. Suppliers found to violate this policy will be required to take immediate corrective action.
• The company will not knowingly support or deal with any business involved in slavery or human trafficking.
• A regular internal audit and review are conducted of the Company’s practices for checking all employees have appropriate right-to-work documents, are paid fairly and enjoy a competitive remuneration package.
• The Company encourages its employees and suppliers to report any concerns or suspicions of modern slavery or human trafficking. We will not tolerate any form of retaliation against individuals who report such concerns in good faith.
• The Company will continue to develop its commitment to fight modern slavery and will provide training and awareness programs to its employees and suppliers to ensure understanding of the risks and signs of modern slavery and human trafficking, as well as the importance of compliance with this policy.