AI Use & Transparency Policy

1. Purpose

The purpose of this Policy is to establish the principles governing the professional use of Artificial Intelligence (AI) by Steg Procurement.

This Policy defines how AI systems may be used to support consulting, analytical, operational, documentation, research and business activities while maintaining appropriate standards of confidentiality, professional responsibility, transparency and human oversight.

For requests relating to the protection of personal data, Steg Procurement may be contacted using the details above or through the forms available on the website.
No sensitive data should be sent via website form unless strictly necessary.

2. Scope

This Policy applies to all Artificial Intelligence systems used by Steg Procurement in a professional capacity.

This includes, but is not limited to:

• • General Purpose AI (GPAI) systems;
• • Large Language Models (LLMs);
• • Generative AI systems;
• • AI-assisted productivity tools;
• • AI-enabled data analysis tools;
• • Future AI systems integrated into Steg Procurement workflows.

This Policy applies to all activities performed under the Steg Procurement brand, regardless of the specific AI provider, platform or technology used.

3. Regulatory Reference

Steg Procurement recognizes Regulation (EU) 2024/1689 (Artificial Intelligence Act) as the primary regulatory framework governing Artificial Intelligence within the European Union.

Steg Procurement adopts a proportionate and risk-based approach to AI governance consistent with the objectives of the AI Act, including:

• • Human oversight;
• • transparency;
• • accountability;
• • responsible data management;
• • reliability and accuracy of outputs;
• • professional responsibility for decisions and actions.

Steg Procurement acknowledges that AI systems are support tools and not autonomous decision-makers.

This Policy shall be interpreted in conjunction with applicable data protection legislation, including Regulation (EU) 2016/679 (General Data Protection Regulation - GDPR), where personal data is processed.

4. Permitted AI Use

Steg Procurement may use Artificial Intelligence systems as professional support tools for operational, analytical, documentation, organizational and non-autonomous decision-support activities, including but not limited to:

• • analysis and interpretation of data;
• • procurement and sourcing-related activities;
• • document and contract drafting support;
• • reporting and content generation;
• • development of tools, models and automation solutions;
• • research, planning and scenario evaluation;
• • knowledge management and information organization;
• • administrative and business support activities.

AI-generated outputs may be used to support professional activities but shall not replace professional judgment.

All external deliverables remain subject to human review and validation prior to use or distribution.

5. Data Handling & Confidentiality

Steg Procurement applies the principle of data minimization when using AI systems.

Whenever reasonably possible, information provided to AI systems should be limited to the minimum data necessary to perform the intended task.

Depending on project requirements, Steg Procurement may:

• • use anonymized data;
• • use pseudonymized data;
• • use coded identifiers;
• • use business information provided by clients as part of legitimate consulting activities.

Where project execution requires the use of identifiable business information, such information may be processed in accordance with contractual obligations, applicable privacy regulations and client instructions.

Steg Procurement does not intentionally use AI systems to process information that is prohibited by law or contractual obligation.

6. Human Oversight

Human oversight is a fundamental principle of Steg Procurement's use of Artificial Intelligence.

AI systems may assist in generating analyses, recommendations, summaries, drafts or alternative scenarios.

However:

• • AI systems do not make final business decisions;
• • AI systems do not approve contractual commitments;
• • AI systems do not approve commercial commitments;
• • AI systems do not act as autonomous representatives of Steg Procurement.

Final responsibility for all professional decisions remains with Stefano Gottardis operating under the Steg Procurement brand.

7. Output Validation

AI-generated outputs may contain inaccuracies, omissions, outdated information or inappropriate recommendations.

For this reason:

• • AI outputs shall be reviewed before professional use;
• • material findings should be assessed using professional judgment;
• • significant conclusions should be verified when appropriate;
• • client-facing deliverables shall be subject to human validation.

The level of validation applied may vary according to the nature, complexity and potential impact of the output.

Steg Procurement maintains responsibility for the final content of all deliverables provided to clients.

8. Responsibilities

Steg Procurement does not intend to transfer personal data outside the European Economic Area as part of the normal operation of the website and contact form.

Responsibilities include:

• • selecting AI tools that are appropriate for the intended use, taking into account factors such as functionality, reliability, security, privacy controls and applicable legal requirements;
• • defining acceptable use practices;
• • protecting confidential information;
• • reviewing AI-generated outputs;
• • maintaining human oversight;
• • monitoring significant regulatory developments.

AI providers remain responsible for the development, operation and maintenance of their respective systems in accordance with applicable laws and regulations.

9. AI Transparency Principles

Steg Procurement is committed to transparency regarding the use of Artificial Intelligence.

AI systems may be used as support tools during the delivery of consulting services, internal operations and business activities.

Steg Procurement may use AI-assisted processes as part of its professional service delivery. Where appropriate, clients may be informed of such usage and specific project requirements may be addressed on a case-by-case basis.

The use of AI does not alter Steg Procurement's professional responsibilities, contractual obligations or accountability for delivered work.

10. Review and Updates

This Policy shall be reviewed periodically to ensure continued alignment with:

• • applicable legislation;
• • regulatory guidance;
• • business operations;
• • technological developments;
• • evolving AI governance practices.

Steg Procurement reserves the right to amend this Policy at any time where necessary to maintain effectiveness, accuracy or compliance.

11. Document Control