Artificial Intelligence Usage Policy

Artificial Intelligence (AI) is the theory and development of computer systems or tools able to perform tasks that normally require human intelligence.

Different types of AI can:

• look for patterns in data and use them to make predictions or recommendations;
• communicate using natural human language; or
• create new content like text, images and computer code, known as generative AI.

AI technologies present significant opportunities within the industry, offering the potential to enhance productivity, efficiency and service quality across a Agent’s operations and services. However, the use of AI also introduces legal, ethical and operational risks.

Cutis Associates recognises these benefits and risks and supports the responsible and appropriate use of Approved AI Tools by its workers.

Approved AI Tools means AI Tools as may be approved from time to time.

Purpose

Preservation of the Agent’s data security, intellectual property, and confidentiality is paramount in all Agent activities, including the use of AI tools.

Approved AI Tools are not stand-alone solutions but are part of a wider set of resources to assist the Agent’s workers in their roles. They should be used to supplement, not replace, traditional methods of primary research and due diligence (especially in field), problem-solving and decision-making.

The output of Approved AI Tools should always be supplemented by the Agent’s workers who have a duty to:

• check and verify from independent and original sources the accuracy of research conducted and
• all AI generated or assisted results are to be referred to the Licensee-in-charge for final verification and approval.

This Policy establishes rules for the use of Approved AI Tools across the Agent’s business activities, setting out the responsibilities of workers to protect information and to act in accordance with the Agent’s legal, professional and ethical obligations.

Scope, Application and Review

This Policy applies to all Workers of the Agent. Worker means employees, contractors (including sub-contractors), volunteers, work experience students or labour-hire employees, to the extent that they use AI in the performance of their work for the Agent, whether at the Agent’s office(s) or elsewhere (for example, when working remotely).

The obligations on Workers using Approved AI Tools includes, but is not limited to, compliance with upholding privacy and anti-discrimination laws, maintaining confidentiality of information, and ensuring the security of all data processed through AI systems.

This Policy does not form a contract, or part of any contract, between the Agent and any of its Workers. To the extent that this Policy requires Workers to do or refrain from doing something, it forms a direction of the Agent with which Workers must comply.

The use of Approved AI Tools is subject to the guidelines contained within this Policy, and in compliance with other relevant policies of the Agent.

For the avoidance of doubt, the use of non-approved AI tools is a breach of this Policy.

Any suspected or actual misuse of AI (including Approved AI Tools) or breach of this Policy must be immediately reported to the Licensee-in-charge.

A Workers’ non-compliance with this Policy may result in disciplinary action, up to and including termination of their employment or engagement with the Agent.

Authorised Use of Approved AI Tools

The Approved AI Tools provided by the Agent are for business use only and should not be used for personal purposes or activities. This Policy is in place to ensure the maintenance of a professional environment, the preservation of company resources, and to prevent potential legal and security risks.

Only Workers authorised by the Agent (Authorised Agent Worker) and who have received the necessary training are permitted to use the Approved AI Tools, in the manner authorised by the Agent. Such authorisation is necessary to ensure that Authorised Agent Workers are aware of the capabilities and limitations of these the Approved AI Tools. Authorised Agent Workers must therefore not use any other AI tools other than the Approved AI Tools.

Authorised Agent Workers are permitted to make appropriate, responsible and effective use of the Agent’s Approved AI Tools in the performance of their work. This includes, but is not limited to, work in connection with the Agent’s business or operations to support productivity, creativity, communication, efficiency and service quality.

The following are some examples of the ways in which the Agent’s Workers can use Approved AI Tools to increase productivity, efficiency or increase the quality of their work.

• history of a property, its street and suburb
• vendor searches
• flooding history and risks
• local crime rates
• major local infrastructure and other projects
• local amenities.

Administrative Support

• Automating repetitive data entry tasks, such as populating Agent databases, updating contact information, or tracking lease milestones, subject to appropriate review and privacy safeguards;
• Assisting with the collation and basic analysis of property market data (e.g., rental trends, comparable sales, or vacancy rates) for internal planning and reporting purposes only.

Review, verification and correction of AI generated work

The Agent’s Workers should have a clear understanding of the Approved AI Tools they use, including that there are risks regarding the non-reliability of the results generated by AI. Accordingly, Workers are expected to complete adequate reviews of all AI generated work or output to avoid bias, errors or inaccuracies in their work.

All Workers who use the Approved AI Tools must not rely only on outputs or results from these tools and must critically evaluate and verify from independent sources all such outputs to ensure as reasonably possible any work generated or created using these tools is accurate. AI-generated output/results can be used as a starting point but must be carefully scrutinised. These outputs/results should be critically analysed for accuracy and bias, supplemented, and improved, if necessary.

To repeat: all AI generated or assisted results are to be referred to the Licensee-in-charge for final verification and approval.

Copyright

Workers using the Approved AI Tools need to be aware of risks around breach of copyright and plagiarism by generating and using content that closely resembles existing works or that is derived from publicly available content. Workers should ensure that they use the review process always to fact check sources and avoid quoting from or directly using copyrighted or publicly available content without proper attribution.

Unauthorised use of AI

The Agent’s Workers are strictly prohibited from the unauthorised use of AI.

Unauthorised use includes, but is not limited to, usage of non-approved AI Tools (including by Authorised Agent Workers), AI usage by non-authorised Workers (including of Approved AI Tools), AI utilisation beyond the Authorised Agent Worker’s authorised scope of work, or employing AI in manner inconsistent with this Policy or other company policies or guidelines.

Unauthorised AI use may lead to disciplinary action, up to and including termination of employment.

Protection of Confidential Information

The Agent and its Workers have obligations to not misuse or make unauthorised disclosure of Confidential Information.

Confidential Information means all information, except to the extent that it is generally and readily available to the public (other than due to a breach of a Worker’s agreement with the Agent or any other obligation regarding confidential information, including by a third party), of which a Worker becomes aware or generates in the course of, or in connection with their employment or engagement with the Agent relating in any way to the Agent or any associated entity of the Agent, or their former, current, or prospective clients, customers, partners, business associates, officers, employees, contractors, suppliers, or any other persons involved in or associated with the conduct of their business. It includes, without limitation, each of the following:

• information which the Agent or an associated entity of the Agent identifies or marks or treats as confidential;
• information which a reasonable person in their position should understand is confidential;
• sensitive business or personal information;
• Agent’s trade secrets, work, and intellectual property rights;
• agreements, arrangements or terms of trade with clients, customers and suppliers or prospective clients, customers or suppliers;
• names, addresses (including email addresses), phone numbers and all other contact information of sellers, buyers, prospective sellers and buyers of property or any property owner (including their employees, contractors and representatives) on whose behalf a property is managed by the Agent or an associated entity of the Agent;
• contractual and technical information including any passwords, logins, social media handles/hashtags;
• marketing plans and marketing and sales techniques including all PowerPoint and other similar presentations made to prospective clients;
• business plans and forecasts;
• business systems and procedures;
• financial records, reports and accounts (including all template, draft and final property due diligence reports);
• business proposals;
• manuals;
• operational materials;
• details concerning the business affairs of the Agent or an associated entity of the Agent;
• customer/client lists, contacts, information and records (whether or not the client/customer is current, former, or prospective) including, but not limited to, all personal and financial information revealed by customers/clients or potential customers/clients;
• employee and contractor information, including their conduct, performance, client/customer contacts and relationships, employment or contractor agreements and arrangements, remuneration, commissions, fees, and any personal information (but not including a Worker’s remuneration or any terms and conditions of their employment or engagement that are reasonably necessary to determine their remuneration outcomes); and
• legal, tax, and accounting advice.

AI tools often require users to input data to generate results or outputs which can often lead to data leakage or unintended external (outside of the Agent) disclosures of Confidential Information. It is therefore critical that that the Agent’s Workers keep all Confidential Information safe, and to not share any such information except in accordance with this Policy.

Non-disclosure of Personal and/or Sensitive Information

The Agent has obligations under the Privacy Act 1988 (Cth) in relation to Personal Information and/or Sensitive Information that the Agent collects from its Workers, clients, property owners, property buyers / sellers, tenants and other third parties.

Personal Information means:

• information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not; and whether the information or opinion is recorded in a material form or not.

Sensitive Information means:

• information or an opinion about an individual’s racial or ethnic origin, political opinion, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, military or veteran status, or criminal record (that is also Personal Information);
• health information about an individual;
• genetic information about an individual that is not otherwise health information; biometric information that is used for the purpose of automated biometric verification or biometric identification; or
• biometric templates.

It is therefore critical that that the Agent’s Workers do not share any such Personal Information and/or Sensitive Information or data with any AI tools, including Approved AI Tools.

This includes inputting, sharing, processing, using or analysing such information in connection with any AI tools; and anonymising or removing Personal and/or Sensitive Information before providing any inputs or prompts to generate results or work products from AI tools.

Monitoring

The Agent reserves the right to monitor all Worker interactions with AI tools in accordance with its Workplace Surveillance Policy (including with respect to computer surveillance) for the purpose of ensuring compliance with this Policy.

The Agent may vary, replace, or withdraw this Policy from time to time at its absolute discretion.