1. Purpose & Scope

This AI Ethics & Responsible Use Policy (the “Policy”) defines the global standards for the safe, transparent, and responsible use of artificial intelligence (“AI”) across all TrustlessPay Digital Assets, Inc. (“TrustlessPay”) platforms, including its Web 3.0 infrastructure, smart contracts, analytics engines, and governance systems.

This Policy forms a dedicated component of the Global Risk Mitigation Policy and applies to:

• All AI systems used or deployed by TrustlessPay;
• All employees, contractors, vendors, and partners interacting with AI systems;
• All TrustlessPay Web 3.0 products, protocols, and interfaces;
• All AI-enabled compliance, monitoring, and risk-scoring tools.

2. Ethical AI Principles

2.1 Transparency

AI systems must be explainable, traceable, and auditable. Stakeholders must be able to understand what the system does, what data it uses, and how decisions are generated, and must have a clear path to challenge or appeal automated outcomes.

2.2 Accountability

Human oversight is mandatory. Each AI system must have an identified owner, documented approval workflows, and clear escalation paths. No AI system may make irreversible decisions without human review.

2.3 Fairness & Non-Discrimination

AI models must be evaluated for bias, disparate impact, and unfair exclusion. Identified risks must be mitigated and reviewed on a recurring basis.

2.4 Privacy & Data Protection

AI systems must comply with applicable data protection and financial regulations and adhere to TrustlessPay’s internal data minimization and encryption standards.

2.5 Security & Resilience

AI systems must be protected against adversarial attacks, data poisoning, model inversion, and unauthorized access, and must align with TrustlessPay’s cybersecurity framework.

2.6 Human-Centered Design

AI must augment, not replace, human judgment. Employees must be trained on AI limitations, escalation procedures, and appropriate use.

3. AI Risk Categories

AI-related risks are integrated into TrustlessPay’s Global Risk Mitigation Framework and include, at minimum:

• Financial AI Risk: AI used in fraud detection, treasury automation, token modeling, and market surveillance.
• Cybersecurity AI Risk: AI exposed to adversarial threats, smart contract interactions, and infrastructure security.
• Operational AI Risk: Process failures, misconfigurations, and unsupervised automation loops.
• Regulatory & Compliance AI Risk: AI used for AML/KYC, sanctions screening, and transaction monitoring.
• Third-Party AI Risk: Vendor-provided models, datasets, and APIs.
• Human Risk: Over-reliance on AI outputs and misuse by personnel.
• ESG & Ethical AI Risk: Social, environmental, and human rights impacts.

4. AI Lifecycle Governance

TrustlessPay governs AI systems across their full lifecycle:

• Design & Development: Threat modeling, bias testing, data provenance checks, and secure development.
• Deployment: AI Governance Committee approval, documented intended use, and human-in-the-loop requirements.
• Monitoring: Key risk indicators, drift detection, continuous compliance checks, and anomaly reporting.
• Decommissioning: Secure retirement, data deletion, and documentation archiving.

5. AI Incident Response

AI-related incidents, including model failures, biased outcomes, security breaches, and regulatory violations, are handled under TrustlessPay’s Crisis Response Plan and must be escalated to the Incident Response Team, Chief Risk Officer, AI Governance Committee, and, where material, the Board of Directors.

6. AI in Web 3.0 & Smart Contract Environments

AI systems interacting with on-chain infrastructure must comply with additional safeguards:

• Smart Contract Interaction: AI may not deploy or modify smart contracts or execute treasury actions without human approval.
• DAO Governance: AI may support analysis and simulation but may not replace human or community governance.
• Token Economy Modeling: AI-driven simulations must be transparent, stress-tested, and reviewed for manipulation risk.

7. Intellectual Property, Trademarks & Licensing

This AI Ethics & Responsible Use Policy is the intellectual property of TrustlessPay Digital Assets, Inc.

© 2026 TrustlessPay Digital Assets, Inc. All rights reserved.

“TrustlessPay,” the TrustlessPay logo, and related names, designs, and slogans are trademarks or service marks of TrustlessPay Digital Assets, Inc. (“TrustlessPay Marks”). “IVAA” and any associated logos or marks (“IVAA Marks”) are trademarks or service marks owned or controlled by their respective rights holders and are used by TrustlessPay under authorization. No use of the TrustlessPay Marks or IVAA Marks, TrustlessPay name, TrustlessPay brand is permitted without prior written consent, except as expressly allowed in a written agreement.

8. Version Control & Governance

This Policy is reviewed at least annually, or more frequently as required by regulatory, technological, or business changes. Updates are approved by the Board of Directors and recorded in TrustlessPay’s policy repository with version history.

9. Integration with Global Risk Mitigation Policy

This AI Ethics & Responsible Use Policy is formally incorporated into the TrustlessPay Global Risk Mitigation Policy and constitutes the authoritative AI Global Risk Mitigation Policy for all AI-related activities across TrustlessPay’s Web 3.0 and enterprise ecosystem.