ARTIFICIAL INTELLIGENCE (AI) POLICY

ANGELO CALVI & PARTNERS LTD

Document Reference: ACP-AI-001
Version: 1.0

Effective Date: August 2026
Approved by: Managing Director

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1. PURPOSE

Angelo Calvi & Partners Ltd recognises Artificial Intelligence (AI) as a strategic technology capable of improving productivity, creativity, research, communication and innovation across the organisation.

The purpose of this Policy is to ensure that AI is used responsibly, ethically, transparently and in compliance with applicable legislation, including the European Union Artificial Intelligence Act (EU AI Act), the UK General Data Protection Regulation (UK GDPR) and other relevant legislation.

Artificial Intelligence is considered a professional support tool.

It shall never replace human judgement, professional responsibility or organisational decision-making.

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2. SCOPE

This Policy applies to:

* Angelo Calvi & Partners Ltd * Coolvoyage Destinations * Coolvoyage Sardinia * Coolvoyage London * Coolvoyage Phuket * Coolvoyage Plus

It applies to:

* directors * employees * consultants * contractors * interns * volunteers * collaborators acting on behalf of the Company.

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3. PRINCIPLES

The Company adopts the following principles.

Human Responsibility

Every output generated through Artificial Intelligence remains under the responsibility of the Company.

AI never makes final decisions.

Humans do.

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Transparency

The Company uses Artificial Intelligence as a professional support tool.

Whenever legally required, users interacting with AI systems will be informed accordingly.

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Accuracy

AI-generated content shall always be reviewed before publication.

Verification remains a human responsibility.

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Confidentiality

Confidential information shall not be disclosed to AI systems unless expressly authorised and compatible with applicable contractual and legal obligations.

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Fairness

Artificial Intelligence shall not be used to discriminate against individuals or organisations.

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4. PERMITTED USES

Artificial Intelligence may be used for:

* research * project development * Erasmus+ proposal drafting * report preparation * brainstorming * communication * digital marketing * social media * website drafting * translation * proofreading * data organisation * content planning * graphic concepts * educational material * tourism destination analysis

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5. PROHIBITED USES

The following activities are prohibited unless specifically authorised.

* Uploading confidential client documents. * Uploading personal sensitive information. * Uploading health records. * Uploading financial information belonging to clients. * Uploading passwords. * Uploading confidential contracts. * Generating fake official documents. * Generating misleading information intentionally. * Using AI to impersonate individuals.

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6. HUMAN REVIEW

Every document produced with AI shall be reviewed before:

publication;

delivery to clients;

submission to funding authorities;

publication on websites;

distribution to partners.

The reviewer shall verify:

accuracy;

consistency;

legal compliance;

language quality;

factual correctness.

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7. WEBSITE CONTENT

Artificial Intelligence may support the creation of:

articles;

blog posts;

project descriptions;

marketing copy;

web content.

Every published page shall undergo editorial review.

The Company assumes full editorial responsibility for every published content.

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8. AI GENERATED IMAGES

AI generated images may be used for:

illustrations;

concept art;

infographics;

educational graphics;

visual mock-ups.

Images shall not intentionally misrepresent:

real destinations;

real people;

real events;

real projects.

Whenever appropriate, the Company may indicate that illustrations have been generated using Artificial Intelligence.

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9. COPYRIGHT

Users shall verify that AI-generated content does not knowingly infringe:

trademarks;

licensing agreements;

intellectual property rights.

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10. DATA PROTECTION

Users shall comply with:

UK GDPR;

Data Protection Act;

applicable contractual obligations.

Sensitive personal information shall not be entered into publicly available AI systems.

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11. APPROVED AI SYSTEMS

The Company currently authorises the use of:

OpenAI ChatGPT

Claude

Microsoft Copilot

Google Gemini

Canva AI

Additional tools may be approved by Management.

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12. AI LITERACY

All personnel using AI shall maintain an adequate level of knowledge regarding:

AI capabilities;

AI limitations;

AI risks;

hallucinations;

bias;

data protection;

responsible use.

The Company supports continuous learning on Artificial Intelligence.

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13. RESPONSIBILITY

The Managing Director retains overall responsibility for:

AI governance;

policy implementation;

review of AI usage;

approval of new AI tools.

Every collaborator remains personally responsible for verifying outputs generated through AI.

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14. BREACHES

Failure to comply with this Policy may result in:

withdrawal of AI access;

internal disciplinary measures;

contractual action where applicable.

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15. REVIEW

This Policy shall be reviewed annually or whenever significant legislative changes occur.

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AI POLICY STATEMENT

Angelo Calvi & Partners Ltd believes that Artificial Intelligence should enhance human creativity, professional expertise and innovation.

Artificial Intelligence is a tool.

Responsibility always remains human.