Artificial Intelligence (AI) Policy

Governance Committee Approval on behalf of the Board
Signed by Chris White, Group Chief Operating Officer

Attention Industries, encompassing all entities, brands and trading styles operated by the group, is committed to the responsible use of Artificial Intelligence (AI).

Our guiding principle is human oversight. AI is used to assist and augment our team and is not a replacement for human creativity, consultancy and quality.

All work that has AI involvement will undergo full human review before distribution.

We strive to use AI and AI Agents to deliver more efficient and effective services for our clients, allowing our team to focus on creativity, enhance the wellbeing of our team and to improve the business.

We recognise that the responsible, effective use of AI is of benefit to society and the economy. We commit to being transparent, fair & unbiased, secure.

We expect all suppliers, contractors and freelancers to adhere to Attention Industries’ AI Policy.

Transparency, disclosure and authenticity

Our AI Policy is publicly available.

Where we are aware of it, we will disclose the use of AI whenever it plays a significant or essential role in the creation of our content or work.

If we create ‘realistic’ content predominantly with the assistance of AI, we will always disclose it.

We never knowingly publish or distribute content (written or visual) that has been created 100% by AI without full disclosure.

We use AI image, writing and data tools to check and improve content.

We recognise that some clients require content that is entirely free from generative AI involvement. Where formally requested, we will use best endeavours to provide a service free from AI-generated content. In cases, where AI is used to generate text, images or video for use in news articles the AI content will be clearly labelled: in text through an advisory at the start of the article, in photographs through an on-image notice and embedded metadata, and in video through an on-screen disclosure.

Human oversight

All use of AI is subject to human oversight and is checked before use, publication or distribution.

This includes a mandatory human review stage for all publisher-facing content and newswire materials.

The Human Bullseye

The Human Bullseye sets out, where Attention Industries draws the line between human-centric work and automated work. It moves from the centre outwards: the bullseye represents activities that remain wholly human, and each successive ring introduces a greater proportion of automation, with the outer ring becoming fully automated over time.

This framework is the practical expression of our “human oversight” principle and should be read alongside every other section of this policy.

How to read this:

Ring 1 — Undivided Attention
Client Engagement
Some work is irreducibly human. The strategic thinking, creative judgment, and relationship intelligence that defines our best work cannot be delegated — to anyone, or anything. In Ring 1, AI plays no role. This is where our people show up fully, and where our clients experience us at our most distinct.

Ring 2 — Active Attention
Project Management & Content Creation
Our people lead; AI removes friction. In content, that means AI may draft, research, or iterate — but the ideas, the voice, and the final call belong to a human. In project management, AI surfaces information faster and keeps work moving, but every meaningful decision is made by a person. The work is ours. The tools just make us sharper.

Ring 3 — Periodic Attention
Business Operations
AI handles execution within parameters we define. A named human owner reviews outcomes at regular intervals — ensuring quality, catching drift, and maintaining the standards our clients expect. Oversight is structured, not incidental.

Ring 4 — Background Attention
Paperwork
AI runs the process. A human remains accountable for the outcome. Our governance model ensures that wherever AI operates autonomously, a named owner has signed off on the guardrails — and is responsible if they fail. Efficiency without abdication.

AI literacy and ethics

All colleagues at Attention Industries undertake an AI literacy course covering the ethical and responsible use of AI.

All colleagues are committed to continuous professional development to improve their use of AI.

AI use

Attention Industries uses AI and AI Agents for a range of tasks including, but not limited to:

• Automation of processes — routine, repeatable tasks that benefit from consistency and speed.
• Deep research — conducting in-depth research or receiving regular research updates where links and citations are provided so sources can be verified.
• Ideation — we may use AI to assist initial strategy, research and insight ahead of our creative brainstorming process to help us meet a client brief.
• Market research — we may use AI to aid question and answer generation to ensure a thorough questionnaire is created. A member of the research team will always review the wording and decide whether generated content is right to keep.
• Data analysis and dashboards — our online dashboards include AI-generated insight for each question to highlight top stats and any interesting differences.
• Content creation support — AI is used as a supportive tool, enhancing and assisting the creative content process rather than replacing it.
• Summaries and analysis — producing content summaries and analytical breakdowns.
• Internal training — training teams on presenting, new product offerings and outbound sales calls.

Accuracy, fact-checking and combatting disinformation

We will not use AI to create, alter or change content in a way that misleads, either intentionally or unintentionally.

Privacy, data protection and responsible sharing

We prioritise data protection and privacy as set out in our Privacy Policy.

We do not allow staff, contractors or third parties to share any personal, confidential or sensitive information with AI tools unless we understand that the licence and terms of use make it safe and secure to do so.

We will only share confidential information with commercial paid AI tools where the licence terms ensure the information remains private and is not shared with the tool’s large language model or datasets, nor used for its training purposes.

If information is already publicly available, we may use free AI tools where the terms state it might be included in the large language model or used for training purposes.

Intellectual property and copyright compliance

We recognise there are intellectual property and copyright issues regarding the use of AI large language models.

We always endeavour to comply with all relevant legislation.

Where relevant, we use tools from suppliers (such as Microsoft and Adobe) that provide an indemnity against the inadvertent use of copyrighted material.

If we use AI-generated replicas, we will disclose the use of AI.

Personal use

Colleagues at Attention Industries are encouraged to experiment with free AI tools for personal use.

If a tool is identified as having potential for professional use, a request form is submitted, and the tool is checked before permission is granted to use it at work. This applies to both free and paid tools.

Third-party AI use

Attention Industries recognises that content distributed via the SWNS newswire may be processed by SWNS’s customers using their own AI tools and technology.

Currently licenced AI tools

The following AI tools are currently licenced and used by Attention Industries

• Copilot for Microsoft 365
• Claude
• Adobe (Firefly / Creative Cloud generative tools)
• Yoodli
• Midjourney
• Notion AI
• Magai
• Abacus AI

The company may update this policy at any time at its discretion.