Appendix

Cotality’s Approach to Artificial Intelligence

Cotality routinely reviews opportunities for process improvements and product offerings that may benefit from using AI capabilities for future enhancement. Cotality manages the use of AI through a Corporate Program that requires the approval of all AI by the enterprise-wide Artificial Intelligence Governance Committee (AIGC).

Cotality has established and designed the Artificial Intelligence Governance Program (AIGP) to ensure best practices, maintain integrity and trust, and meet the specific expectations communicated by various regulators. The AIGC reviews all requests to ensure all proposed solutions are technically sound, ethically responsible, and that the staff using AI are provided appropriate guidance and direction.

For an AI functionality in any product to be deemed releasable, the AIGC must reach the unequivocal conclusion that the innovation does not compromise Cotality's reputational risk.

Cotality is guided by a set of mission, vision, and operational principles that lay the foundation for objectivity and fairness internally and externally. These two qualities are at our core, both as a business and in our approach to innovation. We are committed to fostering a culture of trust and transparency, and acting with integrity in all our technological developments. There are no black boxes around any of our solutions.

Cotality's primary goal for every AI model is to present data and make decisions objectively and fairly. We are committed to mitigating bias by using certifiably objective and representative data to train our models, ensuring that the output is fair, and never inappropriately favors or disfavors any person or policyholder. All AI models undergo rigorous ethical testing before release.

Ultimately, we will not release a solution if it poses any reputational risk.