Modern slavery
disclosure

Introduction

Our Ethical Obligation to Human Dignity and Fairness

Modern slavery is a serious global issue that affects millions of people. It includes slavery, human trafficking, servitude, forced labour, debt bondage and child labour. These abuses often occur out of sight, but that doesn’t diminish our responsibility to act.

At AAA Private Wealth Advisors, we are committed to conducting business in a way that respects the rights and freedoms of all individuals. This disclosure outlines the steps we take to identify and mitigate risks of modern slavery within our own operations, across our investment portfolios, and throughout our third-party supply chains.

In line with the Modern Slavery Act 2018 (Cth), we are proud to publish our position and ongoing efforts to eliminate exploitation, uphold ethical standards, and promote responsible business conduct.

Our Organisation and Operating Structure

Who We Are and What We Do

AAA Private Wealth Advisorsis an Australian-based wealth management firm providing personalised investment and financial services to individuals, advisers, and corporate clients.

Our operations include:

• Internal professional teams, including advisers, analysts, and client service staff
• External suppliers such as software vendors, legal and compliance consultants, IT providers and marketing agencies
• Partnerships with platform providers, custodians, and investment product issuers

We acknowledge that as a financial services provider, our direct risk of modern slavery is low, but we may be indirectly exposed through outsourced services and global supply chains.

Identifying Risks of Modern Slavery

OWhere Vulnerabilities May Exist

We regularly assess the potential for modern slavery risks across three main areas:

• Direct Operations: Our internal staffing practices comply with Australian workplace laws. We provide fair pay, safe conditions, and inclusive hiring practices. All employment is voluntary.
• Supply Chain: We work with various third-party vendors, some of whom may have operations or sourcing networks in higher-risk regions. This includes technology, printing, marketing, facilities, and office consumables.
• Investments: We consider ESG (Environmental, Social and Governance) factors, including modern slavery, when analysing investment opportunities or working with product issuers. Investment in companies that have poor human rights practices is a key concern.

Actions We Take to Address Modern Slavery Risks

From Policy to Practice—Our Approach

We have implemented a number of practices to prevent and respond to potential modern slavery issues, including:

• Modern Slavery Policy: Sets out our internal expectations for ethical conduct across all teams and partners.
• Supplier Due Diligence: We assess key suppliers for risk, including their geographical operations and industry type.
• Contractual Controls: Wherever possible, we include human rights and modern slavery clauses in our supplier agreements.
• Staff Awareness: Our teams receive training on modern slavery and ethical sourcing to support informed decision-making.
• Investment Screening: We engage with managers and product issuers who factor modern slavery risk into their ESG analysis.

We are also developing enhanced internal frameworks for supplier onboarding and risk monitoring.

Assessing the Effectiveness of Our Actions

Monitoring, Reporting and Continuous Improvement

To assess the impact of our efforts, we:

• Review and update our modern slavery risk register annually
• Track supplier engagement and compliance measures
• Monitor ESG ratings and controversies related to investee companies
• Set internal goals for improved ethical procurement practices
• Conduct periodic reviews of high-risk suppliers or regions

We recognise that addressing modern slavery is a continuous journey, and we are committed to strengthening our oversight and transparency year by year.

Governance and Accountability

Ethical Leadership Starts at the Top

AAA Private Wealth Advisors’s Board of Directors oversees our approach to modern slavery compliance. Responsibility for implementation is shared across key functions, including:

• Compliance & Risk
• Procurement & Operations
• Investment Management
• Corporate Governance

Senior leaders are accountable for upholding our ethical standards, and we encourage all staff to speak up if they witness or suspect unethical conduct at any level.

Reporting and Future Focus

Looking Ahead—Raising the Standard Further

As part of our ongoing commitment, we will:

• Enhance engagement with suppliers around modern slavery expectations
• Incorporate clearer ESG risk indicators into investment decision-making
• Work with industry peers and professional bodies to share knowledge and improve practices
• Refine our reporting mechanisms and public disclosures for greater transparency

We are determined to lead with integrity and play our part in building a future free from exploitation.

Statement of Compliance

In Line With the Modern Slavery Act 2018 (Cth)

This disclosure is made pursuant to the requirements of the Modern Slavery Act 2018 (Cth) and reflects AAA Private Wealth Advisors’s operations and policies during the relevant financial year. It has been reviewed and approved by our Board of Directors.

Need to Report
an Ethical Concern?

We Take All Reports Seriously

If you are aware of or suspect unethical conduct—including modern slavery—within our operations, investment holdings, or suppliers, we encourage you to report it confidentially.