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California Compliance Statement

Last Modified January 1, 2025

This statement is provided by Tempus AI, Inc. (“Tempus,” “our,” “us,” or “we”) pursuant to California Health & Safety Codes §§ 119400-119402 (“the California Code”) which requires pharmaceutical and certain medical device companies to adopt and attest to having a Comprehensive Compliance Program that conforms with HHS-OIG guidance and industry codes. 

Our mission is to help patients live longer, healthier lives through precision medicine. Ethics, integrity, and compliance are essential parts of the Tempus culture and fundamental to fulfilling our mission. To that end, Tempus has developed and implemented a Comprehensive Compliance Program (“Tempus Compliance Program”) in accordance with the HHS-OIG guidance (“General Compliance Program Guidance and Model Compliance Plan for Clinical Laboratories” and “General Compliance Program Guidance”), the AdvaMed “Code of Ethics on Interactions with US Health Care Professionals,” and the California Code, among others. 

The Tempus Compliance Program is designed and implemented to prevent, detect and address potential or actual instances of non-compliance and applies to all Tempus employees and affiliates including contractors, officers, directors, board members, distributors, and subsidiaries (“Tempus personnel”). All Tempus personnel are expected to comply with the Program, the company’s policies and procedures, and all applicable laws, regulations, and industry codes.

Following is an overview of the Tempus Compliance Program which is reviewed and updated periodically to meet changing regulatory, legal and compliance requirements.

Written Policies and Procedures

Tempus has developed and implemented policies and procedures to help ensure compliance with applicable laws and promote ethical decision making. The written policies and procedures address key potential risk areas facing clinical laboratories and medical device manufacturers as identified in the AdvaMed Code and HHS-OIG Guidance, including ethical and compliant interactions with healthcare professionals. Tempus has also established a specific annual dollar limit on educational items and promotional activities Tempus may give or otherwise provide to an individual medical or healthcare professional.

Tempus periodically reviews and updates the policies and procedures to ensure compliance with all laws, regulations, and guidance and to reflect changes in the industry. All Tempus employees are required to read, understand, and abide by the policies and procedures.

Leadership and Oversight

Tempus’ senior leadership team is charged with overseeing and administering the Tempus Compliance program. The General Counsel maintains primary oversight and works closely with other members of the Tempus Legal and Compliance teams, as well as with members of Human Resources, Finance and other business units, as appropriate, to develop, monitor, implement, and enhance the Tempus Compliance Program.

Training and Education

All Tempus commercial employees receive appropriate compliance training which includes education on HHS-OIG Guidance, healthcare fraud and abuse laws (including anti-kickback, false claims, and physician self-referral), privacy laws, billing practices, and guidelines for compliant and ethical interactions with healthcare professionals. 

Tempus regularly reviews and updates compliance training materials and deploys role-based and ad hoc compliance training on an as needed basis.

Auditing and Monitoring

Tempus has established internal monitoring and auditing systems to prevent, detect, and address potential or actual instances of non-compliance. The scope and target of audits may evolve in response to legal and regulatory updates, past audit results, industry trends, and changes in business operations.

Lines of Communication

Tempus values open communication and provides multiple avenues for submitting reports of potential misconduct or compliance concerns.The information provided will be treated confidentially to the extent possible. All Tempus employees are required to report any potential compliance violations in a timely manner and each reported matter is appropriately investigated and addressed. 

Tempus strictly prohibits and does not tolerate any form of retaliation against any individual for reporting suspected misconduct in good faith.

Investigations and Corrective Action

The Tempus General Counsel oversees the timely investigations of reported potential misconduct to ensure timely, complete and objective investigations. Tempus employees are expected to cooperate in any investigation. 

Tempus strictly prohibits and does not tolerate any form of retaliation against any individual for cooperating in an investigation.

CALIFORNIA ANNUAL DECLARATION OF COMPLIANCE

Tempus is committed to conducting business ethically and in compliance with applicable laws and regulations. We declare, to the best of our knowledge and belief and based upon a good faith understanding of the California Code, that Tempus is in material compliance with the California Code for the reporting year January 1, 2024-December 31, 2024. 

Tempus is committed to the continuous evaluation, development, and improvement of its compliance program to ensure it is adequately designed and implemented to prevent, detect and address potential or actual instances of non-compliance. Copies of this summary of the Tempus Compliance Program and annual declaration of compliance may be obtained from this web page, by contacting Tempus Compliance at compliance@tempus.com or the following toll-free number: (800) 739-4137.