How is the Code of Conduct used in practice?
First and foremost, the Code of Conduct gives all our AI engineers a framework through a set of high-level principles, that they need to work within. Among other things, it helps to work towards ensuring: that our AI systems are subject to human oversight, and that they respect and promote human agency; that they are technically robust, resilient, and safe, so we prevent unintentional harm to individuals; that we comply with privacy and data protection laws; and that decisions or predictions that they produce can be explained to customers and are free from unfair bias or discrimination.
Every AI ‘use case’ (i.e. any significant deployment of AI, such as a credit lending model) undergoes an Ethical AI Impact Assessment to explore if it could unintentionally exhibit any ethical risks. The assessment is reviewed by a dedicated AI & Data Ethics team. Use cases deemed high risk, referred to as ‘edge cases’, are formally discussed in the AI and Data Ethics Panel which evaluates the ethical concerns based on the principles in the Code of Conduct and makes recommendations as to how potential ethical risks should be mitigated.
The Panel is comprised of colleagues drawn from right across the bank to help provide the widest diversity of thoughts and opinions. Panel members are required to complete a set of training modules which qualifies them to sit on the Panel. For every Panel meeting, we then select from this diverse pool of trained people.
Each member on the Panel represents our different stakeholder groups – including customers, colleagues, communities, shareholders & investors, and future generations. Their individual roles are to challenge the ‘edge case’ business owner on that specific aspect. The Panel offers guidance on necessary measures to minimize ethical risks.
We also only adopt technologies which we have been rigorously tested in safe, ‘sandbox-type’ environments.
