> For the complete documentation index, see [llms.txt](https://trustcenter.syntphony.com/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://trustcenter.syntphony.com/trust-center/global-assets-responsible-ai-statement.md).

# Global Assets Responsible AI Statement

## Introduction

At NTT DATA, we recognize the transformative potential of Artificial Intelligence (AI) to enhance the capabilities of our Global Assets, drive innovation, and create greater value for our customers and their users. As a trusted partner, we are committed to upholding the highest standards of compliance, governance, and ethical AI practice across our Global Assets guided by the [NTT Group AI charter](https://group.ntt/en/group/ai/charter.html).

Our AI Governance practice is aligned with a broad range of global frameworks and standards, including ISO/IEC 27001, the NIST AI Risk Management Framework and the EU AI Act. &#x20;

Additionally, NTT DATA is a signatory to both pillars of the [AI Pact](https://digital-strategy.ec.europa.eu/en/policies/ai-pact#ecl-inpage-What-is-the-AI-Pact?), an initiative of the European Commission, and has been recognized by the European Commission as [success story in the field of AI literacy](https://digital-strategy.ec.europa.eu/en/policies/ai-literacy-practices/ntt-data-europe-latam).&#x20;

This Statement sets out how these commitments translate into practice in our Global Assets business: the principles that guide the AI components we build and integrate, how we govern and manage AI-related risk throughout their lifecycle, and the transparency we provide to our customers.

***

## AI principles for Global Assets

We apply six core AI principles throughout the design, integration, deployment, and operation of AI within our Global Assets:&#x20;

* **Sustainable Development:** We aim to positively impact society through responsible innovation and enable sustainable development for people, society, and the planet.&#x20;
* **Human Autonomy**: We do not replace human oversight and accountability with AI technologies, and we incorporate human monitoring, verification, and intervention where appropriate to ensure responsible and effective use.&#x20;
* **Fairness and Openness**: We implement processes to identify, test for, and mitigate bias and provide clear, transparent and accessible information about our AI technologies, including their capabilities and limitations.&#x20;
* **Security**: We apply robust security measures aligned to industry best practices and maintain a comprehensive vulnerability management program to identify, manage, and mitigate risks.&#x20;
* **Privacy**: We prioritize privacy and data protection by embedding privacy by design principles and applying appropriate safeguards that comply with global privacy and data protection laws.
* **Communication and Co-creation**: We collaborate with diverse stakeholders to foster the growth and adoption of AI technologies that are inclusive, responsible, and trusted by all.&#x20;

***

## How we build AI in our Global Assets

The Global Assets Unit develop and deliver end-to-end solutions that integrate trusted third-party AI systems and services, such as OpenAI, Azure OpenAI, Google Gemini, Amazon Bedrock and Anthropic. &#x20;

These are integrated under controlled orchestration, expert prompt engineering, and dedicated guardrails, and NTT DATA does not use Customer data to train its own AI models or the models of any third-party AI provider. &#x20;

Their use is subject to each provider's own terms and conditions:&#x20;

* **Model lifecycles**&#x20;

AI models are subject to lifecycles defined unilaterally by their vendors, and may be modified, replaced, or deprecated at any time. &#x20;

NTT DATA monitors provider roadmaps and deprecation notices and takes the reasonable measures within its reach to preserve the functionality of the Global Asset across such changes, including model qualification, regression testing, and migration to successor models. Model changes affecting a Global Asset are communicated in accordance with the applicable Customer Support Policy. &#x20;

NTT DATA does not guarantee the continued availability of any specific AI model. The availability and performance of AI-based functionality remain subject to the service levels of the applicable AI System and Platform Providers, over which NTT DATA has no control (for further information, please see our [Service Level Agreements - Exclusions](https://trustcenter.syntphony.com/trust-center/support-model/service-level-agreements/exclusions)). &#x20;

* **Nature and limitations of AI-generated outputs** &#x20;

AI systems are probabilistic. Outputs may be inaccurate, incomplete, or inconsistent, and identical inputs may produce different results. NTT DATA implements guardrails, input and output filtering, and ongoing monitoring, as described above. These measures reduce, but do not eliminate, this inherent limitation of the technology.&#x20;

Accordingly, NTT DATA does not warrant the accuracy, completeness, or fitness for a particular purpose of AI-generated outputs of our Global Assets. Defining the intended use, validating outputs, and maintaining human oversight proportionate to the risk of the use case are Customer responsibilities. &#x20;

* **Terms of our Global Assets’ third-party model providers and cloud AI services**

**Microsoft Azure**: [Azure Legal Information](https://azure.microsoft.com/en-us/support/legal/), [Azure AI Content Safety](https://learn.microsoft.com/en-us/azure/ai-services/content-safety/), [Abuse Monitoring](https://learn.microsoft.com/en-us/azure/ai-services/openai/concepts/abuse-monitoring), [Responsible Use of AI](https://learn.microsoft.com/en-us/azure/ai-foundry/responsible-ai/openai/overview?context=%2Fazure%2Fai-services%2Fopenai%2Fcontext%2Fcontext), [Microsoft AI Code of Conduct](https://learn.microsoft.com/en-us/legal/ai-code-of-conduct)

**Google Cloud:** [Google Cloud Service Specific Terms](https://cloud.google.com/terms/service-terms), [Responsible AI](https://cloud.google.com/vertex-ai/generative-ai/docs/learn/responsible-ai?hl=en), [Navigating the EU AI Act: Google Cloud's proactive approach](https://cloud.google.com/blog/products/identity-security/navigating-the-eu-ai-act-google-clouds-proactive-approach), [Generative AI and data governance](https://cloud.google.com/vertex-ai/generative-ai/docs/vertex-ai-zero-data-retention?hl=en)

**AWS:** [AWS Service Terms](https://aws.amazon.com/service-terms/), [AWS Generative AI Development Disclosure](https://aws.amazon.com/legal/generative-ai-development-disclosure/), [AWS Responsible AI Policy](https://aws.amazon.com/ai/responsible-ai/policy/)

**Anthropic:** [Anthropic Legal Center](https://www.anthropic.com/legal), [Commercial Terms of Service](https://www.anthropic.com/legal/commercial-terms), [Anthropic’s Responsible Scaling Policy](https://www.anthropic.com/responsible-scaling-policy)

***

## Global Assets AI Governance

Every use case developed by NTT DATA and delivered through our Global Assets undergoes an internal AI risk assessment before reaching production, to confirm the safeguards in place and the regulatory obligations that apply. It remains the Customer's responsibility to use each Global Asset within its intended purpose, approved use cases, and to inform NTT DATA where a specific use case falls outside that purpose, as this may affect the applicable risk classification.&#x20;

These assessments are backed by ongoing monitoring, regular compliance reviews, and the training of everyone involved in building and governing our Global Assets, so that the safeguards described above keep working as intended over time.&#x20;

***

## AI transparency towards end-users

Where a Global Asset is subject to the transparency obligations in Article 50 of the EU AI Act, we comply accordingly, by making sure end-users are clearly informed that they are interacting with an AI system rather than a person, and by disclosing when content such as text, images, audio, or video has been generated or substantially modified by AI.&#x20;

End-Users are expected to use each Global Asset ethically and as intended, avoiding any form of misuse, and reporting any harmful or unsafe behavior they encounter through the established governance channels. These reports, together with any issues identified through our own monitoring, are handled through a dedicated AI incident response protocol: we identify, triage, and address situations where a Global Asset AI component causes or is suspected of causing harm, produces unsafe outputs, or exhibits unexpected behavior, including compliance with applicable regulatory notification timelines. Cases are reviewed through established governance, risk, privacy, security, and incident response processes, and used to support corrective action and continual improvement.

***

## &#x20;**Our commitment to continuous improvement**&#x20;

We are committed to fostering responsible AI in our Global Assets through continuous improvement. NTT DATA invests in research, collaborates with industry leaders and academic institutions, and provides ongoing education so that everyone involved in delivering our Global Assets understands their responsibilities for lawful and ethical AI use. We maintain ongoing monitoring of developments in the regulatory, cybersecurity, technology, and AI landscape, and periodically update the governance frameworks and controls applied to our Global Assets to address emerging risks. &#x20;


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