OVERVIEW

This policy aims to ensure that Mahlab Media Pty Ltd (Mahlab) uses Artificial Intelligence (AI) systems legally, responsibly and ethically.

Mahlab’s AI Policy encompasses the principles, guidelines, and best practices that Mahlab has established to govern our ethical development, deployment, management, and use ofAI technologies.

Mahlab follows the Australian Government’s AI Ethics Principles and Voluntary AI Safety Standard and Guardrails, each as relevant.

PURPOSE

Mahlab embraces new technologies and the positive impact on our industry that they present. Generative AI systems present opportunities to allow more creativity, more productivity and entirely new approaches. Though excited to be leveraging AI’s potential, we remain vigilant about its inherent biases, its security risks and ethical concerns.In keeping with our Code of Conduct, B Corp certification and membership with the Content Authenticity Initiative, Mahlab is committed to operating ethically, securely and transparently, and using AI in a trustworthy, practical, and beneficial manner. The purpose of this policy is to ensure that Mahlab’s use of AI aligns with Mahlab’s values and mission including:

1. responsible innovation

2. quality control and reliability

3. fairness and transparency

4. accountability

5. privacy protection and data security

6. human, societal and environmental wellbeing and human-centred values

7. governance and contestability

SCOPE

This policy explains Mahlab’s approach to utilising generative AI systems and technologies. This includes the development, deployment, management, and use of AI technologies.

PRINCIPLES

1.  Responsible innovation

• Innovation: Mahlab encourages innovation and experimentation with generative AI while maintaining professional and ethical standards.
• Artistic work: Mahlab respects the rights of artists by never using AI to recreate the style or approach of an existing artist.
• Independent intellectual effort and authorship: Mahlab ensures that all services and deliverables have significant independent intellectual effort and authorship by human team members.

2.  Quality control and reliability

• Human oversight: Mahlab has human oversight of selection and use of AI systems and of AI output.
• Review and Validate AI Outputs: Mahlab ensures that AI-generated content and output is fact-checked, verified, reviewed and edited to ensure relevance, originality and compliance before dissemination.
• AI systems reliability: Mahlab monitors and tests AI systems to ensure that AI systems reliably operate in accordance with their intended purpose.

3.  Fairness and transparency

• Communication and disclosure: Mahlab uses AI in all aspects of our business and our service delivery.
• Inclusive and accessible: When Mahlab chooses AI systems, it aims to ensure that AI systems are fair and enable inclusion.
• Bias: Mahlab oversees AI use and AI production decisions. Mahlab aims to ensure that AI produced decisions are compliant with anti‐discrimination laws. Mahlab ensures that AI-generated content and output is reviewed for biases before dissemination, because of the risk for AI to perpetuate societal injustices and have a disparate impact on vulnerable and underrepresented groups including, but not limited to, groups relating to age, disability, race, sex, intersex status, gender identity and sexual orientation.
• Transparency: Mahlab has transparency around AI use including for our team deploying and operating AI systems, to understand processes and input data.

4.  Accountability

• Accountability: Mahlab has assigned responsibility for and maintains accountability measures for Mahlab’s use of AI systems, data and AI-related decisions.
• Leadership: Mahlab has appropriate leaders with specific obligations for safe and responsible development and use of AI across our organisation.
• Impact: Mahlab regularly assesses the impact of AI on our team, clients and other stakeholders. We adjust our AI policy and practices as needed.

5.  Privacy protection and data security

• Privacy: Mahlab’s use of AI systems must adhere to Mahlab’s Privacy Policy.
• Personal and confidential information: Mahlab does not share personal information (as defined in the Privacy Act 1988 (Cth)), or confidential information, into any AI model unless we are certain that data will not be used for training purposes. The only exception is if the training is for Mahlab’s exclusive use, for example, Custom GPTs.
• Anonymised data: Mahlab ensures data inputted into AI is anonymised and secure.
• Consent: Mahlab will obtain explicit consent from clients before using client proprietary data in AI systems.
• Storage: Mahlab ensures that data including personal information is stored and processed in accordance with Mahlab’s Information Security Policy, and legal requirements including the Privacy Act 1988 (Cth) which contains the Australian Privacy Principles.
• Security: Mahlab prioritises data security in our use of data and throughout the design, development and deployment of our data and use of AI, in accordance with Mahlab’s Information Security Policy.

6.  Human, societal and environmental wellbeing and human-centred values

• Human, societal and environmental wellbeing: Mahlab uses AI systems for legitimate internal business purposes such as increasing efficiency and for beneficial outcomes for individuals, society and the environment.
• Human-centred values: Mahlab uses AI in human-centred ways, to support, complement and enhance human creativity, not replace it.
• Human oversight: Mahlab maintains meaningful human oversight when Mahlab designs, develops and deploys AI.

7.  Governance and contestability

• Guidelines: Mahlab has internal guidelines to ensure AI systems are used in alignment with this policy and Mahlab’s purpose and values.
• Governance: Mahlab ensures that roles and responsibilities relating to AI are defined and documented, including decision-making capabilities, functions, and roles.
• Training: Mahlab holds regular training sessions on AI use and AI best practices.
• Records: Mahlab maintains records to show we have adopted and are complying with guardrails. This includes maintaining an AI inventory and consistent AI system documentation.
• Review, Monitor and Evaluate: Mahlab reviews its AI use and collects feedback regularly to ensure accuracy, data security and privacy, minimise negative effects of bias, ensure accessibility and remove ethical prejudices.
• Reporting: Mahlab ensures AI-related concerns can be reported to Mahlab management.
• Legal Compliance: Mahlab ensures all AI applications comply with relevant Australian laws and regulations, including the Privacy Act 1988 (Cth), the Australian Human Rights Commission guidelines on AI, and B Corp commitments.

BREACH

Non-compliance with this policy may result in action up to and including termination of relationship.

REVIEW

This policy will be reviewed annually or as needed to ensure its effectiveness and relevance. Mahlab reserves the right to modify this policy as necessary to adapt to new technologies and regulatory changes.Date: 30 October 2025