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AI Governance & Accountability Who owns your AI and checks its decisions · 3 actions + AI register with clear owners One register of every AI tool in use, with its purpose, data, risk level and owner; reviewed every 6 months. UNGC 1, 2 · Measure: % of AI systems registered with an ownerHuman approval for high-impact AI decisions A named person approves any AI decision on payments, contracts, hiring, pay or dismissal. UNGC 1, 6 · Measure: % of high-impact decisions reviewed by a personAI incident reporting A simple way to report AI errors, bias or harm; every case logged and fixed. UNGC 1 · Measure: Incidents reported; average days to resolve
Data, Privacy & Transparency Protecting data and being open · 3 actions + No AI training on data without consent Recorded consent before personal data is used to train AI, including by third-party providers. UNGC 1 · Measure: % of training datasets with consent recordsLabel AI-generated content AI-made text, images and voice are labelled, and customers know when they are talking to AI. UNGC 1 · Measure: % of AI content labelledData breach transparency Affected people notified within 72 hours; incidents reported each year. UNGC 1 · Measure: Time to notify after an incident
People & Skills in the AI Era Preparing and protecting your people · 4 actions + AI training for every employee A minimum of e.g. 12 hours a year on safe AI use for all staff, including leaders. UNGC 6 · Measure: Average training hours per employeeEmployee voice in AI adoption Affected teams are consulted and test new AI tools before rollout. UNGC 3 · Measure: Number of employee consultationsReskill before redundancy Retraining and an internal role are offered before any AI-related redundancy. UNGC 3, 6 · Measure: % of affected employees redeployedFair treatment of gig and contract workers At least local minimum wage, safe conditions, clear terms and a complaints channel. UNGC 3, 4 · Measure: % of contractors with basic protections
Climate & Planet Measuring and cutting your footprint · 4 actions + Full emissions disclosure Scope 1, 2 and 3 emissions published yearly (GHG Protocol; ideally IFRS S2). UNGC 7, 8 · Measure: Disclosure published; scopes coveredAI and cloud energy disclosure Electricity used by AI and cloud, and its renewable share, published yearly. UNGC 8, 9 · Measure: kWh used; % renewableSupplier climate targets Our 20 largest suppliers measure emissions and agree reduction targets with us. UNGC 8 · Measure: % of top suppliers with targetsGreen purchasing Carbon, energy and recyclability criteria weighted in every major purchase. UNGC 8 · Measure: % of spend meeting green criteria
Responsible Capital & Investment Investing and rewarding responsibly · 6 actions + AI and ESG risk in investment decisions AI risks (bias, privacy, governance) assessed with ESG in every new investment. PRI 1 · Measure: % of assets assessedActive ownership on responsible AI We use our votes and dialogue to ask investees for AI policies and disclosure. PRI 2, 3 · Measure: Engagements held; % of portfolio disclosingSustainability-linked executive pay e.g. 10–20% of executive bonuses tied to measurable sustainability or AI targets. UNGC 10 · Measure: % of variable pay linked to targetsNo greenwashing Every green or ethical claim checked against data, with evidence kept on file. UNGC 8 · Measure: % of claims verifiedSupport impact businesses and local SMEs e.g. 5% of purchasing or investment to social enterprises and local small businesses. UNGC 8 · Measure: % of spend or investmentAnnual responsible investment report ESG and AI risk assessment, engagement and voting published yearly (PRI framework). PRI 6 · Measure: Annual report published
Health & Wellbeing Supporting the people who work with you · 3 actions + Mental health support Confidential counselling for all staff, and managers trained to spot stress. UNGC 1 · Measure: Employee uptake rateCarer-friendly workplace Flexible hours and carer leave for staff caring for children or relatives. UNGC 6 · Measure: Uptake among eligible employeesNeuro-inclusive and age-friendly workplace Recruitment and work adapted for neurodivergent and older employees. UNGC 6 · Measure: Retention rate of these employees
Integrity & Youth Protection Acting with integrity, protecting young people · 3 actions + Protected whistleblowing An anonymous, ideally independent channel; every report investigated, no retaliation. UNGC 10 · Measure: Cases handled; average days to resolveLobbying and political donation transparency Donations, lobbying spend and trade-association memberships published yearly. UNGC 10 · Measure: Published each yearSafe-by-design for young users Safest settings by default, minimal data and a child-safety review before launch. UNGC 1, 5 · RDY · Measure: % of products with a child-safety review
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Be specific. Strong examples will be featured in the final Commitment.
Area Optional Choose one AI Governance & Accountability Data, Privacy & Transparency People & Skills in the AI Era Climate & Planet Responsible Capital & Investment Health & Wellbeing Integrity & Youth Protection Other
1. What will you commit to? Optional e.g. Human review of every AI-assisted credit decision across our 12 branches.
2. How will you put it into practice? Optional
3. What value will it create? Optional e.g. Fairer lending decisions for our customers.