Responsible AI policy

Introduction

At Native Teams, we help businesses employ, pay and manage people across borders, and we help individuals work and get paid wherever they are. Our work touches people's jobs, income and personal information, which is why we believe that any technology we use, including artificial intelligence, must be used carefully, transparently and with people firmly in control.

Artificial intelligence can help us respond to our customers more quickly, find information more easily, reduce manual work and spot problems earlier. We use it where it genuinely improves the service we provide, and only in ways that we can explain, oversee and stand behind. This Policy sets out the principles we follow, how we use AI, how we do not use it, and the safeguards we have put in place.

Scope of this Policy

This Policy applies to the use of artificial intelligence across the Native Teams group, including on our website, in the Native Teams Platform and mobile applications, in our customer support channels and in our internal operations. It applies to AI systems that we build ourselves and to AI tools and services that we obtain from third-party providers.

In this Policy, "artificial intelligence" or "AI" means any system that uses machine learning, large language models or similar techniques to generate content, make predictions or recommendations, or otherwise support decisions. It does not include the conventional rules-based software that performs fixed calculations according to predefined rules, although we apply the same high standards of care to that software.

This Policy applies to everyone who works for or on behalf of Native Teams, including our employees and contractors, and we expect the providers we work with to meet equivalent standards.

Our principles

Our use of AI is guided by the following principles. They reflect our values as a business and the principles set out in internationally recognised frameworks for trustworthy AI.

• People stay in control. AI supports the work of our people, and it does not replace their judgement. A person is always accountable for the decisions that matter to our customers and the people they employ.
• Transparency. We are open about where and how we use AI, we tell people when they are interacting with an AI system, and we explain our use of AI in clear and simple language.
• Fairness. We take care to ensure that our use of AI does not lead to unfair treatment or unlawful discrimination against anyone, whatever their background, nationality or personal circumstances.
• Privacy and security. We protect personal data used in or by AI systems to the same high standard as all other personal data we handle, and we use only the data that is necessary for each purpose.
• Accuracy and reliability. We test AI systems before we use them, we monitor how they perform, and we design our processes so that errors can be identified and corrected.
• Proportionality. We use AI only where it serves a clear and legitimate purpose, and we choose the least intrusive approach that achieves that purpose.
• Accountability. We maintain clear ownership of every AI system we use, and we keep our approach under regular review as technology, regulation and best practice develop.

How we use AI

We use AI in limited and clearly defined ways. Our current uses fall into the following areas.

Helping you find information

We use AI to help customers, workers and visitors find the information they need more quickly, for example through search and assistant features in our Help Centre, in the Platform and on our Legal & Compliance Hub. These features answer questions using the information that we have published or that is available to you in the Platform, and where possible they show you the source of each answer. Answers provided by AI assistants are for information only and do not constitute legal, tax or financial advice.

Supporting our teams

Our team members use approved AI tools to help them work more efficiently, for example by summarising long documents or conversations, translating content, and searching our internal knowledge. In every case, a member of our team reviews the output, remains responsible for what is sent or decided, and can edit or discard the AI's suggestion.

Processing documents and information

We may use AI to help read and organise information from documents that are uploaded to the Platform, such as identity documents, invoices, receipts and payroll information, and to highlight information that appears to be missing or inconsistent. This helps to reduce manual data entry and catch errors earlier. The results are checked through our processes before they are relied upon.

Keeping the Platform safe

We may use AI to help detect unusual activity, potential fraud and security threats, so that we can protect our customers, their people and their funds. Where such a tool identifies a potential concern, the matter is reviewed by a member of our team before any action is taken that could significantly affect a customer or an individual.

Improving our products

We may use AI to help us understand how the Platform is used in aggregate, to identify where our products and services can be improved, and to support our engineers in building and testing software. Where we do so, we use aggregated or de-identified information wherever possible.

How we do not use AI

Just as important as how we use AI is how we choose not to use it. We have set clear limits that reflect the sensitivity of our work and the trust our customers place in us.

• We do not use AI to make decisions that have legal or similarly significant effects on a person without meaningful human review. This includes decisions about whether to employ, engage, discipline or dismiss someone, decisions about a person's pay or benefits, and decisions to refuse or close an account.
• We do not use AI to determine the pay of any person. Salaries, taxes and statutory contributions are calculated by our rules-based payroll systems in line with the applicable law and the information provided, and our specialists remain responsible for the results.
• We do not use AI to recognise or infer the emotions of workers, and we do not use AI to categorise people according to sensitive characteristics such as their ethnic origin, political opinions, religious beliefs, health or sexual orientation.
• We do not use AI to monitor, score or rank the behaviour or performance of the people who are employed or paid through our Platform.
• We do not allow third-party AI providers to use our customers' data, or the personal data of the people they employ or pay, to train their general-purpose AI models.
• We do not sell personal data, and we do not use AI to build profiles of individuals for advertising purposes.

Before we introduce any new use of AI that could fall outside these limits, we will assess it carefully under our governance process, make sure that it complies with all applicable laws, and update this Policy before the new use begins.

Human oversight

Human oversight is at the heart of our approach. For every AI system we use, we identify the people who are responsible for overseeing it and make sure they have the knowledge, authority and time to do so effectively. Those people can review, question, correct and override the output of the system, and they are trained to recognise its limitations and to avoid placing undue reliance on it.

Where AI supports a process that could affect a person's employment, income or access to our services, a member of our team makes the final decision. That decision is based on a genuine assessment of the relevant information, and not simply on acceptance of what the AI system suggests.

Transparency and your rights

We believe that people have a right to know when AI is being used in a way that affects them. Where you interact directly with an AI system, such as a chat assistant, we will make clear that you are interacting with AI, unless that is already obvious. Where the law requires, we will also label content that has been generated or substantially altered by AI.

If you believe that a decision affecting you has been influenced by AI, you can ask us to explain the role that AI played, ask for the decision to be reviewed by a member of our team, and express your point of view or contest the decision. These rights are in addition to your rights under data protection law, including your rights to access, correct and delete your personal data and to object to certain types of processing.

You can exercise these rights by contacting our data protection team at legal@nteams.com. We will respond within the time limits set by law, and we will not treat you less favourably for exercising your rights.

Data protection and AI

Any personal data used in connection with AI is processed in accordance with applicable data protection laws, including the UK General Data Protection Regulation and the EU General Data Protection Regulation, and in accordance with our Privacy Policy, our Individual Privacy Notice and our Data Processing Agreement.

Before we begin any new use of AI that involves personal data, we identify a lawful basis for the processing, limit the data used to what is necessary for the purpose, and assess the risks to the people concerned. Where the processing is likely to result in a high risk to individuals, we carry out a data protection impact assessment before it begins.

Where we use third-party AI providers to process personal data on our behalf or on behalf of our customers, we put appropriate contracts in place that restrict how the data can be used, require it to be kept secure and confidential, and prevent it from being used to train the provider's general-purpose models. Any international transfer of personal data is protected by the safeguards required by law.

Where an AI feature in the Platform is optional, administrators of business accounts can choose to switch it off for their organisation.

Choosing and managing AI providers

We select our AI providers carefully. Before we start working with a provider, we assess its approach to security, privacy, reliability and responsible AI, and we review the contractual commitments it is willing to make. We continue to monitor our providers throughout our relationship with them, and we will stop using a provider if it no longer meets our standards. Providers that process personal data on behalf of our customers are listed among our sub-processors.

Governance and risk management

We manage AI through a structured governance process that is led by a cross-functional group with representatives from our legal, compliance, data protection, information security, product and engineering teams. This group is responsible for approving new uses of AI, maintaining this Policy, and overseeing how AI is used across the business.

We maintain an internal register of the AI systems we use, which records the purpose of each system, the data it uses, the people responsible for it and the safeguards that apply. Before a new AI system is deployed, or an existing system is used for a new purpose, we assess its risks, including risks to privacy, security, fairness and accuracy, and we decide whether and how it can be used safely.

Once a system is in use, we monitor its performance and review it regularly. If we identify a problem, such as inaccurate or biased output or a security issue, we investigate it promptly, take appropriate action, which may include suspending the system, and notify the people affected where that is required or appropriate.

Our approach is informed by recognised frameworks for the responsible management of AI, including the ISO/IEC 42001 standard for AI management systems and the NIST AI Risk Management Framework, where applicable, and it is integrated with our wider information security and data protection programmes.

Legal and regulatory compliance

We comply with the laws and regulations that apply to our use of AI in each country where we operate. These include the EU Artificial Intelligence Act, data protection laws such as the UK and EU General Data Protection Regulations, the rules that apply to automated decision-making, and employment, equality and consumer protection laws.

The EU Artificial Intelligence Act places particular obligations on AI systems that are used for purposes such as recruitment and decisions about work relationships, which it classifies as high-risk. Our current uses of AI are not intended for those purposes. If we ever decide to introduce such a use, we will do so only after meeting all of the applicable legal requirements and updating this Policy.

The regulation of AI is developing quickly, and many obligations are being introduced in stages. We monitor these developments closely and update our practices so that we continue to meet our obligations as they take effect.

Our people and AI literacy

We make sure that the people who work for Native Teams understand both the benefits and the limitations of AI. Team members who use AI tools receive training on how to use them responsibly, how to recognise errors and bias, and how to protect confidential and personal information.

Our team members may use only the AI tools that have been approved for business use, and they must not enter confidential information or personal data into any tool that has not been approved for that purpose. Our internal guidance on acceptable use of AI sets out these rules in more detail.

When our customers use AI

Many of our customers use AI in their own businesses, and some may connect their own AI tools to the Native Teams Platform, for example through our API. Customers are responsible for the AI tools they choose to use, including the permissions they give those tools and the instructions those tools submit to the Platform.

Where our customers use AI to support decisions about the people they employ or engage through Native Teams, they remain responsible for ensuring that those decisions are lawful, fair and subject to appropriate human oversight, in line with the employment and data protection laws that apply to them. We encourage all of our customers to apply the same principles that we apply to ourselves.

Raising a question or concern

If you have a question about how we use AI, or if you are concerned that AI has been used in a way that is inconsistent with this Policy, please contact us at legal@nteams.com or support@nteams.com. We take every concern seriously and will respond as quickly as we can.

Our team members and others connected with Native Teams can also raise concerns, including anonymously, under our Whistleblowing Policy. We do not tolerate any form of retaliation against anyone who raises a concern in good faith.

Review of this Policy

We review this Policy at least once a year, and more often where our use of AI, the law or best practice changes significantly. The date at the top of this Policy shows when it was last updated, and we will highlight significant changes on our Legal & Compliance Hub.