Modern Day Slavery & Human Trafficking Policy

Policy Statement

At Tempus Wealth, we are committed to a zero-tolerance approach to exploitation, modern slavery, human trafficking, and coerced or forced labor in every regard. We operate with integrity, transparency, and ethical conduct within our corporate structure, our operational partnerships, and our investment philosophies. We strive to be good corporate citizens with each day of operation.

Modern Day Slavery is a crime and a violation of fundamental human rights. Modern Day Slavery takes various forms, such as slavery, servitude, forced or compulsory labor, coercion, and human trafficking, all of which deprive a person's liberty, to the benefit of another, in order to exploit them for personal or commercial gain. We are committed to acting ethically and with integrity in each of our relationships and take caution, implementing and enforcing effective systems and controls where needed. These efforts are made to ensure Modern Day Slavery is not taking place within Tempus Wealth or in any of the firm’s relationships.

This policy applies to all persons and institutions who wish to be associated with, or act on behalf of Tempus Wealth in any capacity, including:

  • Employees at all levels, officers, and directors.

  • External consultants, contractors, and third-party representatives.

  • Business partners, suppliers, and service providers.

Identifying Risks in Wealth Management & Professional Services

While the financial services and wealth advice sector is generally considered "low risk" for direct forced labor, we recognize that risk exposure exists indirectly. We actively monitor and manage risks across two primary pillars:

Corporate Supply Chains

We audit and evaluate vendors that provide operational support to our offices and digital infrastructure, prioritizing higher-risk service sectors including:

  • Facilities Management: Cleaning, waste management, and office security services.

  • Information Technology: Sourcing of hardware, electronics, and digital infrastructure components.

  • Corporate Gifting & Hospitality: Sourced merchandise, catering, and event vendors.

Investment Management & Advisory

As a wealth advice platform, we recognize our responsibility to promote ethical allocation of capital. We strive to:

  • Incorporate Environmental, Social, and Governance (ESG) criteria into our investment analysis where applicable.

  • Encourage clients and portfolio managers to look closely at the supply chain transparency of multinational corporations held within portfolios.

Supplier Due Diligence

We expect our suppliers to hold their own supply chains to the same high ethical standards. As part of our procurement and onboarding processes, we:

Evaluate: Assess the modern slavery risks of any new core supplier based on their geographic location and industry sector.

Attest: Require high-risk or major operational vendors to confirm their compliance with relevant international frameworks (such as the UK Modern Slavery Act 2015, Modern Slavery Act, or local equivalents).

Review: Reserve the right to terminate relationships with suppliers who fail to improve conditions or violate basic labor standards upon review.

Reporting & Whistleblowing

We encourage transparency. Employees and external partners are required to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains at the earliest possible stage.

Internal Escalation: Any suspicion of forced labor or human trafficking must be reported immediately to Corey D. Boller, CFA.

Protection: We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place.

Governance & Annual Review

The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

Management at any level is responsible for ensuring those reporting to them understand and comply with this policy. This policy will be reviewed annually to measure effectiveness and update our due diligence processes against evolving regulatory standards.