1. Purpose
This policy describes how Suter Lim & Co Global Advisory (SLC) uses artificial intelligence tools in its advisory practice. It is provided to clients, partners, enterprise procurement teams, and other stakeholders who wish to understand our AI use practices and the safeguards we apply.

SLC advises organisations on AI governance, supply chain transformation, and leadership capability. We apply the same governance standards to our own AI use that we recommend to clients. This policy is a standing public disclosure, not a legal document.

2. Scope
This policy applies to all AI tools used by SLC personnel in the course of delivering advisory services, developing intellectual property, conducting research, and producing client deliverables. It covers SLC's operations across all jurisdictions in which it operates. As an entity registered in Switzerland, SLC's baseline obligations are governed by the nFADP. Client engagements are subject to additional or more stringent data protection requirements under local law, where local requirements shall apply concurrently.

3. SLC’s Role Under AI Regulation
SLC uses third-party AI tools as a productivity and research aid. Under the EU AI Act (Regulation 2024/1689), SLC operates in the capacity of a Deployer as defined under Article 3(4): an entity that uses an AI system under its own authority for non-personal purposes in a professional context.
As a Deployer, SLC maintains the following obligations:
•    Human oversight of all AI-assisted outputs, consistent with SLC’s obligations as a deployer under the EU AI Act framework and Article 25 (responsibilities along the AI value chain).
•    Transparency to clients and stakeholders regarding the nature and extent of AI use, consistent with Article 50.
•    No use of AI systems that would qualify as prohibited under Article 5 of the EU AI Act.

SLC does not develop, train, or place AI systems on the market. It does not act as a Provider under the EU AI Act.


4. AI Tools Used

AI tools are used as productivity and research aids only. All professional judgment, methodology, recommendations, and deliverables are the work product of SLC and are reviewed, validated, and owned by SLC personnel.
 

5. Data Handling Restrictions
SLC maintains the following firm restrictions on AI use. These restrictions are enforced through internal policy, personnel training, and technical controls:

• SLC does not input client-identifiable data into any third-party AI system.
• SLC does not input client company names alongside sensitive, confidential, or commercially sensitive information into AI tools.
• SLC does not input client financial data, regulatory findings, audit results, or personal data into AI tools.
• SLC does not input information subject to a non-disclosure agreement into AI tools.
• SLC does not rely solely on AI output for professional recommendations. All advice is reviewed, validated, and owned by SLC.

All client-specific analysis, diagnostics, and deliverables are produced using client data within a controlled, access-restricted local environment operated by SLC personnel. A “controlled local environment” means a working environment that is not connected to, and does not transmit data to, any third-party AI system or cloud-based AI processing service.

6. Data Privacy & Multi-Jurisdictional Compliance

6.1 Tool Selection Criteria
AI tools used by SLC are selected against explicit, documented criteria. Eligible tools must:

• Operate under a published privacy policy that prohibits training on user-submitted content by default, without the user opting in;
• Support verified data deletion on request;
• Be consistent with the requirements of the EU AI Act, Swiss nFADP, and applicable data protection law in the jurisdictions served; and
• Be reviewed and reconfirmed annually, and reassessed whenever the provider updates its privacy or data processing terms.

Tool eligibility is assessed and documented by the SLC policy owner. No AI tool is adopted without completing this assessment.

6.2 Cross-Territory Standard
Where SLC serves clients across multiple jurisdictions, the most protective data protection standard applicable to the client’s jurisdiction governs SLC’s handling of that client’s data. This principle applies regardless of where SLC personnel are located at the time of the engagement.

7. Human Accountability
SLC maintains that humans are ultimately accountable for all advice, recommendations, and deliverables. AI tools support SLC’s work. They do not replace professional judgment, methodology, or accountability to clients.

This principle is consistent with the governance standards SLC advises clients to apply to their own AI systems, including ISO 42001:2023, the EU AI Act, NIST AI RMF, IMDA and the OECD Principles on Artificial Intelligence.

8. Transparency & Disclosure
SLC publishes this policy as a standing disclosure of its AI use practices. AI and data handling provisions are included in engagement agreements as a standard term, not an optional addition.

SLC reviews this policy annually and whenever there is a material change to its AI use practices or to the regulatory environment. Material changes are communicated to active clients within 30 days of the revised policy taking effect.

SLC deliverables, including reports, frameworks, diagnostic outputs, white papers, or other written work product that contain content developed with AI assistance, will be disclosed to the client in the relevant deliverable or in accompanying correspondence. SLC does not represent AI-assisted content as wholly human-authored without disclosure. Final responsibility for all content that is AI-assisted, irrespective of how it was produced, is the responsibility of SLC.

9. Policy Scope and Limitations
9.1 Policy Status
This policy is a public disclosure of SLC’s AI use practices. It is not a standalone contract or client commitment. Where a client engagement agreement is in force, its terms govern the conduct of that engagement. This policy is reviewed annually and updated when SLC’s AI use practices change materially.

9.2 Third-Party AI Provider Limitation
SLC’s commitments in this policy are contingent on the continued availability and integrity of third-party AI providers’ published terms. SLC will notify active clients within 30 days if a provider changes its privacy or data handling terms in a way that affects SLC’s obligations under this policy. SLC will reassess tool eligibility and update this policy accordingly.

9.3 Intellectual Property
All frameworks, methodologies, diagnostic tools, templates, and outputs developed or produced by SLC, including those developed with AI assistance, remain the exclusive intellectual property of Suter Lim & Co Global Advisory. The SLC 4P Framework™ is a registered trademark of Suter Lim & Co Global Advisory. No AI tool provider acquires any rights to SLC’s intellectual property through the use of SLC’s AI-assisted workflows.

9.4 No Legal or Regulatory Advice
This policy does not constitute legal, regulatory, or compliance advice. Clients and other parties reading this policy should seek independent legal advice regarding their own AI governance obligations.

10. Policy Owner, Version History & Review

Collective Intelligence Statement

This document was produced with AI assistance under human authorship and editorial oversight. SLC uses AI tools ethically and responsibly as part of our practice of governance by example.

Suter Lim & Co Global Advisory (SLC) uses AI tools to support research, drafting, and content development. All content produced through AI assistance is reviewed, validated, and finalised under human authorship by qualified SLC practitioners. This reflects SLC’s commitment to responsible AI use. We govern the AI tools we use, following the same standards we guide our clients to follow. AI assistance does not replace professional judgment; it extends our capacity to serve clients thoroughly and efficiently.

SLC is not a law firm. This document provides governance advisory guidance based on international standards and regulatory frameworks. It does not constitute legal advice. For formal legal counsel, consult a qualified legal advisor in your jurisdiction.