AI Policy

MBL Global

Human Indemnity Following Critical Incidents

1. Purpose

This AI Policy establishes guidelines and best practices for the responsible, ethical, and safe use of Artificial Intelligence (AI) within MBL Global Ltd. It ensures employees, contractors, and partners use AI systems in a manner consistent with the company’s values, legal obligations, regulatory requirements, and the protection of stakeholders.

2. Scope

This policy applies to all employees, contractors, and partners of MBL Global Ltd who use, develop, or interact with AI systems, including but not limited to Large Language Models (LLMs), plugins, and data-enabled AI tools.

3. Policy

3.1. Responsible AI Use

AI systems must be used ethically and responsibly, avoiding any actions that could cause harm, violate privacy, or facilitate malicious or unlawful activity.

3.2. Compliance with Laws and Regulations

All AI use must comply with applicable laws and regulations, including data protection, privacy, intellectual property, discrimination, and professional standards relevant to MBL Global’s operations.

3.3. Transparency and Accountability

  • Employees must clearly disclose when AI is used in decision-making processes.
  • All AI activities, proposals, and deployments must be recorded in MBL Global’s centralized AI governance system (‘AI System of Record’) to ensure accountability.
  • Employees are responsible for the outcomes of AI systems and must be able to explain and justify AI-generated results.

3.4. Data Privacy and Security

  • Personal or sensitive data used in AI systems must be anonymized, pseudonymized, or securely protected.
  • Employees must follow MBL Global’s Data Privacy and Security policies in all AI- related activities.

3.5. Bias and Fairness

  • Employees must identify, monitor, and mitigate bias in AI systems.
  • AI systems must be designed and used to be inclusive, equitable, and non- discriminatory.

3.6. Human-AI Collaboration

  • AI should augment, not replace, human judgment.
  • Employees must apply critical thinking and professional judgment when interpreting AI-generated recommendations.

3.7. Training and Education

  • Employees using AI systems must receive appropriate training to ensure responsible and effective use.
  • Ongoing learning is required to stay informed of technological developments, ethical considerations, and regulatory changes.

3.8. Third-Party AI Services

  • AI systems or services provided by third parties must comply with the same ethical and legal standards outlined in this policy.
  • Employees must verify that vendors and partners adhere to these requirements.

4. Implementation and Monitoring

4.1. AI Governance Board

  • A multidisciplinary AI Governance Board, including data scientists, legal, compliance, ethics, and operational experts, oversees AI initiatives.
  • The Board defines roles, responsibilities, and oversight mechanisms for all AI activities.

4.2. Designated AI Officer

  • Richard Fahrenheim is the current AI Officer responsible for implementing this policy, providing guidance, and ensuring compliance.

4.3. Periodic Reviews

  • The AI Officer will conduct regular reviews of AI use to ensure compliance, identify emerging risks, and recommend policy updates as necessary.

4.4. Incident Reporting

  • Employees must report suspected policy violations, ethical concerns, or legal/regulatory risks related to AI to the AI Officer or through established company reporting channels.

5. Enforcement

  • Violations of this policy may result in disciplinary action, up to and including termination, in line with MBL Global’s disciplinary procedures.

6. Policy Review

  • This policy will be reviewed annually or as needed in response to technological, ethical, or regulatory developments.
  • Any updates will be communicated to all relevant personnel.

7. Effective Date

  • This policy is effective as of 1 July 2023 and remains in force until further revision.
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