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Tingdene AI Policy Document

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ARTIFICIAL INTELLIGENCE (AI) USE POLICY TINGDENE GROUP

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ARTIFICIAL INTELLIGENCE (AI) USE POLICY

1. Purpose The purpose of this policy is to provide clear guidelines for the responsible, lawful and secure use of Artificial Intelligence (AI) tools within Tingdene Group. This policy ensures that AI is used to support business efficiency and decision-making while protecting Tingdene Group’s data, reputation, team members and customers. AI tools are intended to assist team members in their work. They do not replace professional judgement or accountability.

2. Scope This policy applies to all team members employed by Tingdene Group and its subsidiary companies, including permanent, temporary and contracted staff. This policy applies to: • Company-approved AI tools • Publicly available AI platforms • AI features embedded within existing software • Any AI capability used for business purposes This policy should be read in conjunction with Tingdene Group policies: • Disciplinary Policy • Tech Policy & Procedures • Data Retention Policy • Understanding GDPR guidance

3. Definitions Artificial Intelligence (AI) refers to software systems capable of generating, analysing, summarising, interpreting or creating content, data or imagery based on user input. Approved AI tool means any AI platform formally authorised by the Tech Team for business use. Public AI tool means any AI system not formally approved by the Tech Team, including publicly accessible web-based AI platforms.

4. Approved Use Of AI AI tools may be used for the following business purposes: • Drafting or improving written communications • Summarising meetings, meeting notes or transcripts • Supporting analysis of information • Assisting managers in interpreting policies or procedures • Generating non-confidential research, summaries or first drafts

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ARTIFICIAL INTELLIGENCE (AI) USE POLICY

For the avoidance of doubt, AI tools must not be used for automated processing, profiling or decision-making involving personal data unless expressly approved by the Company and undertaken in accordance with this policy and applicable data protection legislation. When using AI tools to analyse, summarise or review documents, team members must only input the minimum amount of information necessary to achieve the intended outcome. Team members should provide relevant excerpts, anonymised sections, or specific passages rather than uploading or inserting entire documents, sensitive information or GDPR protected information. All AI-generated output must be reviewed by the team member before being relied upon or shared. Where AI has been used to assist in the creation of a document, report, presentation, communication or other work product, team members should disclose and be transparent to their colleagues or intended recipients using the following example statement: ‘AI assistance was used in preparation of this document. All content has been reviewed, verified and approved by the author prior to issue’. The team member remains fully accountable for any work produced using AI assistance.

5. Prohibited Use Of AI The following uses of AI are strictly prohibited: • Uploading Tingdene Group confidential, intellectual property, financial, commercially sensitive or personal data into Public AI tools • Uploading business owned material, documents, imagery, contracts, intellectual property or internal reports to non-approved platforms • Creating synthetic or altered images of real individuals without prior approval • Using AI to falsify records, misrepresent facts or generate misleading content • Using AI to harass, discriminate or produce inappropriate material • Circumventing established approval, governance or control processes • Uploading copyrighted third-party material into Public AI tools where doing so would breach licensing, contractual or legal obligations Should any team member be unclear about the use of AI, please contact the Tech Team who will be able to provide further information and guidance. AI must not be used to make final decisions relating to: • Employment or disciplinary matters • Legal determinations • Financial authorisation • Health and Safety risk acceptance

6. Data Protection & GDPR Compliance All AI use must comply with: • UK GDPR • Data Protection Act 2018 • Tingdene Group Data Protection policies 03 | Tingdene Group

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ARTIFICIAL INTELLIGENCE (AI) USE POLICY

Personal data must only be processed using Approved AI tools operating within a secure, tenant-controlled environment. Use of Public AI tools for processing personal data is prohibited. Team members must ensure that: • Data minimisation principles are applied • Information entered into AI systems is appropriate and necessary • Outputs are reviewed for accuracy Any suspected misuse of AI involving personal data, or any suspected data breach involving AI, must be reported immediately via the GDPR Concern reporting process available on the Team intranet site: https:// www.tingdene-employee.net/gdpr-concern. The use of AI does not replace existing obligations relating to confidentiality, information security, data protection or acceptable use of Company systems. Team members must apply the same level of care and judgement when using AI tools as they would when handling information via email, Microsoft Teams, SharePoint, OneDrive or any other Company-approved system.

7. Financial And Confidential Information Financial, commercially sensitive or confidential information may only be processed using Approved AI tools. Such processing must: • Be undertaken by individuals authorised to access the data • Be used for analysis, drafting or decision-support purposes only • Not be relied upon as the sole basis for decision-making Use of Public AI tools for financial or confidential business information is prohibited.

8. Approval Of AI Tools Approval of AI tools is managed by the Tech Team in collaboration with relevant stakeholders. No AI tool may be used for business purposes involving internal information unless formally approved. Approval may be granted for a specific AI tool, a specific use case, or a specific category of information. Requests to: • Add a new AI tool • Amend permitted data use • Seek clarification or exception must be submitted via a Helpdesk request. Where appropriate, a Data Protection Impact Assessment (DPIA) may be undertaken prior to approval. Personal AI accounts or subscriptions must not be used for processing Company information unless their use has been explicitly approved by the Tech Team and complies with this policy.

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ARTIFICIAL INTELLIGENCE (AI) USE POLICY

9. Responsibilities Tech Team • Approve AI tools for business use • Assess security and technical suitability • Maintain oversight of approved platforms Team Members • Use AI responsibly and in accordance with this policy • Review AI-generated output before use • Report suspected misuse, GDPR concerns or data breaches via the GDPR Concern reporting process available on the Team intranet site: https://www.tingdene-employee.net/gdpr-concern. Managers • Monitor and ensure appropriate AI use within their teams • Escalate concerns where misuse is suspected Chief Data Officer (CDO) or designated Company Data Protection Lead • Provide oversight regarding GDPR compliance • Advise on data protection risks associated with AI • Respond to GDPR concerns raised through Company reporting channels • Lead or coordinate interactions with the Information Commissioner’s Office (ICO) where required • Support investigation and governance of AI-related data protection incidents

10. Disciplinary Consequences Failure to comply with this policy may result in disciplinary action in accordance with Tingdene Group’s Disciplinary Policy. Serious misuse of AI, including but not limited to: • Disclosure of confidential information • Deliberate falsification of records • Unauthorised processing of personal data • Conduct bringing Tingdene Group into disrepute may constitute gross misconduct and could result in summary dismissal.

11. Review This policy will be reviewed annually or earlier if required due to regulatory, technological or operational change.

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ARTIFICIAL INTELLIGENCE (AI) USE POLICY

APPENDIX A – Examples Of Artificial Intelligence (AI) Tools The examples below are provided for guidance only and are not an exhaustive list. Inclusion in this appendix does not automatically constitute approval for business use. Approval status must be confirmed with the Tech Team prior to use involving Company information. 1. Generative Text AI Tools – AI systems capable of drafting, summarising or analysing written content. 2. AI Embedded within Business Software – email drafting assistance, document summarisation, data analysis support and meeting transcription tools. 3. Image and Media Generation Tools – images, video, audio and synthetic voice. 4. Analytical AI Tools – forecast modelling, trend analysis, financial modelling assistance and risk analysis support.

APPENDIX B – Approved AI Tools The following AI tools are currently approved for business use, subject to compliance with this policy and any applicable licensing restrictions. AI Tool

Approved Use

ChatGPT

General business productivity, drafting, summarisation, research and analysis in accordance with this policy

Claude

General business productivity, drafting, summarisation, research and analysis in accordance with this policy

Superhuman Email

Email management, email drafting, summarisation and productivity assistance

AI Tools Under Review Microsoft Copilot Microsoft 365 Copilot The Tech Team may review and amend the approved AI tool list from time to time. Any additions or removals will be communicated to team members and reflected within the next published version of this policy.

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Tingdene Group, 34-36 Bradfield Road, Finedon Road Industrial Estate, Wellingborough, Northamptonshire NN8 4HB Tel: 01933 449090

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