ApriCOT Responsible & Ethical AI Policy

At ApriCOT, we believe Artificial Intelligence should augment human capability, not replace human responsibility.

ApriCOT uses AI to support leadership assessment, development planning and coaching. Because these applications may generate insights about an individual's competencies, behaviours and development opportunities, we recognise our responsibility to use AI thoughtfully, transparently and responsibly.

Our approach is guided by applicable law and recognised principles of responsible AI, including the Digital Personal Data Protection Act, 2023 and applicable Rules, the principles reflected in India's Artificial Intelligence (Ethics and Accountability) Bill, 2025, UNESCO's Recommendation on the Ethics of Artificial Intelligence, and other applicable privacy and AI regulations in jurisdictions where ApriCOT is used.

This Policy describes the principles we seek to follow when designing, deploying and improving AI-enabled ApriCOT services.

ApriCOT is designed to support informed human judgement.

AI-generated assessment scores, observations, reports, development recommendations and coaching responses are intended to provide structured insights. They should not ordinarily be treated as the sole basis for significant employment decisions such as hiring, promotion, termination, compensation or disciplinary action.

The organisation using ApriCOT remains responsible for:

• interpreting assessment information appropriately;
• considering relevant contextual and professional information;
• exercising independent human judgement; and
• ensuring that employment or people decisions comply with applicable laws and internal policies.

ApriCOT does not itself make the final employment decision concerning an assessment participant.

We seek to design and operate ApriCOT in a manner that promotes fairness, consistency and equitable treatment.

We recognise that AI systems can reproduce or amplify bias arising from data, methodology, prompts, models or the context in which an assessment is used.

Accordingly, we seek to:

• use defined assessment criteria and competency frameworks rather than irrelevant personal characteristics;
• periodically review assessment methodologies and outputs for material inconsistencies or unintended bias;
• investigate credible concerns regarding unfair or discriminatory outcomes;
• improve systems where meaningful bias or methodology-related concerns are identified; and
• avoid intentionally designing assessments to discriminate on protected or irrelevant personal characteristics.

The 2025 Indian AI Bill similarly proposes that employment-related AI should be subject to safeguards against discriminatory outcomes and ethical review.

Fairness does not mean that every participant will receive the same assessment result; it means that comparable evidence should be evaluated through an appropriately consistent methodology.

Participants and customers should understand when AI is being used and the general purpose for which it is being used.

Where appropriate, ApriCOT will provide information regarding:

• the purpose of an AI-enabled assessment or development activity;
• the nature of information being processed;
• how AI contributes to the assessment, report or coaching experience;
• relevant limitations of AI-generated outputs; and
• who may receive assessment outputs.

We seek to make assessment outputs sufficiently understandable to support meaningful interpretation by participants, assessors and authorised client representatives.

However, transparency does not require disclosure of proprietary source code, trade secrets, confidential scoring logic, security information or intellectual property where such disclosure is not required by law.

Privacy is an integral part of responsible AI.

Personal data used by ApriCOT is handled in accordance with our applicable Privacy Policy, Platform & Assessment Privacy Notice, contractual obligations and data-protection requirements.

We seek to:

• collect information relevant to the stated assessment or development purpose;
• restrict access to authorised individuals;
• use personal data only for disclosed, lawful and appropriate purposes;
• retain information only for appropriate periods;
• implement reasonable safeguards designed to protect personal information; and
• respect applicable participant rights.

Where consent is legally required, it should be obtained in an appropriate and transparent manner.

Our use of personal information is also designed to align with the evolving requirements of India's DPDP framework, including clear notice regarding the information collected and the purpose of processing.

ApriCOT may use authorised third-party AI, cloud or technology providers as components of its Services.

We recognise that responsible AI therefore requires attention not only to technology developed by ApriCOT but also to technology supplied by others.

Where appropriate, we seek to consider factors such as:

• privacy and data-protection arrangements;
• confidentiality obligations;
• information-security practices;
• permitted uses of customer data;
• reliability and suitability of the technology; and
• material changes in the provider's terms or capabilities.

ApriCOT remains responsible for the way it integrates and deploys third-party technologies within its Services, subject to applicable contractual and legal limitations.

Artificial Intelligence is not infallible.

AI systems may produce outputs that are incomplete, inaccurate, contextually inappropriate or affected by limitations in underlying models or inputs.

Accordingly:

• ApriCOT does not represent AI-generated output as an infallible prediction of human behaviour or future performance;
• assessment results should be interpreted in the context of the assessment methodology and intended purpose;
• development recommendations should be treated as developmental guidance rather than guarantees of future outcomes; and
• appropriate human review should be applied when outputs may materially affect an individual.

Customers should use ApriCOT only for purposes for which the relevant tool has been designed.

We seek to take reasonable measures designed to protect ApriCOT systems and information against misuse, unauthorised access, manipulation and other reasonably foreseeable risks.

We may monitor or investigate suspected:

• unauthorised access;
• attempts to manipulate assessments;
• misuse of AI functionality;
• security incidents;
• prohibited or unlawful activity; and
• other activity that could undermine the integrity of the platform or assessment process.

Where appropriate, access may be restricted or suspended to protect participants, customers, systems or information.

Responsible AI requires identifiable human accountability.

ApriCOT seeks to maintain appropriate governance over the design, implementation and use of its AI-enabled capabilities.

Depending upon the nature and risk of a feature, this may include:

• review of assessment methodology;
• testing before deployment;
• review of significant changes;
• periodic monitoring of system performance;
• investigation of material concerns;
• review of privacy and security implications; and
• escalation of significant ethical or operational risks.

UNESCO's ethical framework similarly places emphasis on human oversight, transparency, accountability and impact assessment throughout the lifecycle of AI systems.

Ethical AI is a shared responsibility.

Organisations using ApriCOT are expected to:

• use the Services for lawful and appropriate purposes;
• explain the assessment purpose to participants where required;
• restrict access to reports and outputs to authorised persons;
• maintain confidentiality of participant information;
• avoid treating an AI output as an automatic substitute for professional judgement;
• avoid discriminatory, deceptive or unlawful use of assessment information; and
• comply with applicable employment, privacy and other laws.

ApriCOT is not responsible for independent decisions or uses made by a customer after information has been lawfully provided to that customer, except where responsibility cannot legally be excluded.

AI technologies, regulations and recognised ethical standards continue to evolve.

We therefore intend to review our responsible-AI practices periodically and update this Policy where appropriate to reflect:

• material changes in ApriCOT's technology;
• emerging risks;
• regulatory developments;
• customer and participant feedback;
• developments in responsible-AI standards; and
• lessons identified through monitoring and review.

We may modify, restrict or discontinue an AI-enabled feature where we reasonably determine that its risks cannot be appropriately managed.

We encourage customers, participants and other stakeholders to raise genuine concerns about ApriCOT's use of AI.

Questions or concerns regarding responsible AI may be directed to:

AI Ethics Policy & Grievance contact

Shyne Devasia Kochuveed

Organisation

PeopleWiz Consulting LLP

Email

info@apri-cot.in

Concerns relating specifically to personal data should also be addressed in accordance with the applicable ApriCOT Privacy Policy or Platform & Assessment Privacy Notice.