FINDER & PARTNERS — RESPONSIBLE AI

How we use AI — and what we never let it replace

We use internal intelligence tools to help our people organise information, prepare work and identify matters requiring attention. Technology supports those activities. Material customer-impacting decisions remain subject to authorised human oversight and the applicable client mandate.

HUMAN AUTHORITY · DEFINED PURPOSE · CONTROLLED DATA · ACCOUNTABILITY

Our approach to artificial intelligence distinguishes between tools that support human work and the human authority required for material decisions. AI supports analysis and operational efficiency; it does not replace accountable human judgement.

AUTHORITY ARCHITECTURE
ASSISTANCE ≠ AUTHORITY
AI ASSISTANCE SIGNALS
ANALYSE
ORGANISE
PREPARE
FLAG
RECOMMEND
HUMAN AUTHORITY REQUIRED
Signals STOP at boundary — AI does not cross
AUTHORISED HUMAN JUDGEMENT
APPLICABLE CLIENT MANDATE
MATERIAL CUSTOMER-IMPACTING ACTION
01 — OUR GOVERNING PRINCIPLE

AI can assist judgement. It does not inherit authority.

As artificial intelligence tools become more capable, organisations face genuine governance risks — including over-reliance on automated recommendations, biased or disproportionate outputs, inaccurate generated information, inappropriate use of personal data, unclear responsibility for consequential actions, or automation exceeding the client mandate.

BILATERAL GOVERNANCE ARCHITECTURE
AI Support•Authority Boundary•Human Authority
AI SUPPORT CAPABILITIES
01
ANALYSIS
02
ORGANISATION
03
PREPARATION
04
MONITORING
05
RECOMMENDATION
AUTHORITY BOUNDARY
HUMAN OPERATIONAL AUTHORITY
01
REVIEW
02
CONTEXT
03
JUDGEMENT
04
AUTHORISATION
05
ACCOUNTABILITY
CONSTITUTIONAL GOVERNANCE STANDARD
Material customer-impacting decisions remain subject to authorised human oversight and the applicable client mandate.

Internal intelligence tools are intended to operate inside defined purposes, permissions and workflow boundaries. They may support analysis, organisation, preparation, monitoring or recommendations. They do not replace the accountable person responsible for exercising the applicable authority.

02 — HOW INTERNAL INTELLIGENCE TOOLS MAY ASSIST

Assistance across approved operational workflows.

Depending on the approved workflow, internal tools may support our personnel in specific operational activities:

ACCOUNT ORGANISATION
PORTFOLIO INFORMATION→ORGANISE & PARSE→PERSONNEL REVIEW

Tools may organise account information according to authorised portfolio and workflow parameters so personnel can review relevant information more efficiently. Any prioritisation or recommendation remains subject to applicable client parameters, governance controls and human operational authority.

COMMUNICATION PREPARATION
APPROVED FRAMEWORK→DRAFT & FORMAT→AUTHORISED WORKFLOW

Tools may assist with drafting or organising communication material within approved frameworks. Communications remain subject to applicable authorised workflows and human oversight requirements.

COMPLIANCE / EXCEPTION MONITORING
OPERATIONAL ACTIVITY→IDENTIFY & FLAG→HUMAN ATTENTION

Tools may identify patterns, exceptions or conditions that warrant human attention. A flag is an input for review, not a finding of liability or misconduct.

REPORTING & ANALYTICS
OPERATIONAL DATA→ORGANISE & ANALYSE→INTERNAL / CLIENT REVIEW

Tools may assist in organising operational or compliance information for internal or client review.

03 — BOUNDARIES ON AI AUTHORITY

Assistance has a boundary.

Finder & Partners sets strict operational boundaries around technology. Internal AI tools are not authorised to independently:

AUTHORITY FIREWALL · PROHIBITED INDEPENDENT ACTIONS
NOT AUTHORISED INDEPENDENTLY
✕determine legal liability
✕establish or alter customer obligations
✕approve settlement terms outside authorised parameters
✕make final decisions on disputes or exceptions
✕bypass required human approvals
✕expand access beyond the active client or data scope
✕use customer information for unrelated purposes
Payment Safety Boundary
AI / FINDER & PARTNERS
✕ NO PAYMENT PROCESSING
CUSTOMER → APPOINTING CLIENT AUTHORISED CHANNEL

Finder & Partners does not receive, collect, hold or process customer payments. AI systems therefore do not accept or process customer payments. Payments must be made directly through the authorised channels of the appointing client.

MODEL TRAINING BOUNDARY · CLOSED GOVERNANCE GATE
RESTRICTED
OPERATIONAL CUSTOMER INFORMATION → [ GOVERNANCE GATE: CLOSED ] → GENERAL MODEL DEVELOPMENT

Operational customer information must not be used to train general AI models or for unrelated model development unless a separately authorised, legally permissible and governed process has been approved.

04 — NAYA & KNOWLEDGE BOUNDARIES

Naya provides guidance. It does not become the account system.

Naya is UnitKredit's public assistance and guidance interface. It is designed to assist members of the public, account holders and corporate prospects by providing approved information and routing enquiries.

Naya does not retrieve account-specific operational information through its public knowledge pathway.

NAYA APPROVED PUBLIC SCOPE
approved public information
payment-channel guidance
office and service-location information
general governance and compliance information
corporate and panel enquiry routing
privacy and compliance enquiry routing
NAYA SECURITY CLASSIFICATION & OPERATIONAL ISOLATION
NAYA ASSISTANCE PATHWAY
L0 PUBLICApproved public knowledge
L1 QUALIFIED CORPORATEAuthorised corporate access
L2 VERIFIED CORPORATEApproved disclosure
L3 INTERNAL RESTRICTEDNOT public Naya knowledge
OPERATIONAL ACCOUNT DATA
SEPARATE CONTROLLED ENVIRONMENT

Account-specific information (balances, status, history, dispute records) remains isolated within separate operational environments.

NAYA PUBLIC ROUTING ≠ ACCOUNT DATA ACCESS
Similarity or conversational confidence never increases authorisation.
NAYA GENERATIVE BOUNDARY

Naya is designed to ground responses in approved information and defined access boundaries. Where approved information is unavailable or a request falls outside the permitted scope, the intended behaviour is to decline, clarify or route the enquiry rather than retrieve restricted information. Generated responses may still require human review where appropriate.

05 — HUMAN ACCOUNTABILITY

Technology does not become the accountable party.

“When a decision matters, 'the system suggested it' is not an adequate accountability answer.”

Responsibility for operational decisions remains with authorised personnel acting within their roles and the applicable mandate.

AI-generated recommendations, summaries or drafts do not transfer accountability from the person exercising the relevant authority to the system that assisted them.

Where decisions or actions require an approval record, that record should identify the responsible human role or person according to the applicable operational control.

06 — FAIRNESS AND BIAS

Human oversight matters, but it is not the only fairness control.

DEFENSIVE FAIRNESS LAYERS
01
01 — DEFINED PURPOSE

Use AI only for a documented operational purpose.

02
02 — RELEVANT INPUTS

Use information relevant to that purpose.

03
03 — HUMAN REVIEW

Personnel should be able to question and override tool outputs.

04
04 — OUTPUT MONITORING

Where appropriate, review patterns for anomalous, disproportionate or unintended outcomes.

05
05 — CHANGE CONTROL

Material changes to models, prompts, parameters or automation should be evaluated before broader deployment.

06
06 — ESCALATION

Questionable outputs should be capable of being escalated to authorised personnel.

PROTECTED CHARACTERISTICS STANDARD

Protected or sensitive characteristics should not be used to drive operational treatment unless their use is lawful, necessary for an authorised purpose and specifically governed.

07 — TRANSPARENCY

People should be able to ask how technology is involved.

Account holders and clients may raise questions about how technology supports Finder & Partners' recovery activities. Naya can route responsible-AI or transparency enquiries into the appropriate controlled process.

CONTROLLED TRANSPARENCY DISCLOSURE
APPROPRIATE DISCLOSURE INCLUDES
  • • general role of technology in the relevant process
  • • whether tool assistance formed part of the workflow
  • • the role of human oversight
  • • available review or enquiry pathways
NOT AUTOMATICALLY DISCLOSED
  • • internal prompts and system instructions
  • • security architecture details
  • • restricted model parameters
  • • third-party confidential information
  • • unverified account data
08 — RESPONSIBLE AI COMMITMENTS

Our operational commitments.

HUMAN AUTHORITY
Maintain meaningful human authority over material customer-impacting decisions.
DEFINED PURPOSE
Use AI only within approved operational purposes and applicable client mandates.
CONTROLLED INFORMATION
Apply data-access and information-classification boundaries.
TRANSPARENCY
Explain publicly the general role and limits of AI in our operations.
MONITORING & REVIEW
Review AI-supported workflows according to their risk and operational importance.
CORRECTION
Where an AI-supported process produces inappropriate or unreliable outcomes, investigate and apply appropriate corrective measures.
CHANGE GOVERNANCE
Material expansion of AI authority should require deliberate governance review rather than occur silently through technical change.
MATERIAL EXPANSION OF AI AUTHORITY → DELIBERATE GOVERNANCE REVIEW REQUIRED
NATIONAL GOVERNANCE CONTEXT

MALAYSIA AI GOVERNANCE CONTEXT

VOLUNTARY GOVERNANCE REFERENCE

Finder & Partners considers Malaysia's National Guidelines on AI Governance and Ethics (AIGE) as one relevant reference point for responsible AI governance.

FAIRNESS
RELIABILITY, SAFETY & CONTROL
PRIVACY & SECURITY
INCLUSIVENESS
TRANSPARENCY
ACCOUNTABILITY
PURSUIT OF HUMAN BENEFIT & HAPPINESS
The Guidelines are voluntary and do not constitute statutory certification or replace applicable legal and contractual obligations.
RESPONSIBLE AI ENQUIRIES

Ask how technology supports our work — and where its authority ends.

Ask Naya to identify the appropriate pathway for:

RESPONSIBLE AI
TRANSPARENCY
GOVERNANCE & POLICIES
PRIVACY COMMITMENTS
CORPORATE AI GOVERNANCE
HUMAN OVERRIDE ROUTING

Account-specific enquiries require the appropriate controlled identity and account-authorisation process.

This statement describes the responsible-AI principles applied to AI-assisted tools and public assistance channels used by Finder & Partners Sdn Bhd under the UnitKredit digital identity.

It does not expand Naya's authority or create access to operational customer information.

Our use of AI and related governance controls may evolve. Material changes to the role or authority of AI in our operations should be reflected in this statement.