through on-screen pop-ups if they stray into an area, asking if they have received training in that area. If you don’t provide policies and training, people get curious. Tey want to enable themselves and that can become a problem.”


conversation focused. Tat was the journey we took. A lot of training happened.” Williams added, “We talk a lot about the risks and


“When AI arrived, I don’t think anybody grasped how big it would become. We had to quickly adapt internally and come up with policies and consistency in that space. The consistency is the key to the policy. There are always holdouts and siloes, but that was broken really quickly." - Steven Eliuk, IBM


Elliott asked Eliuk to explain how IBM reacted to


the advent of AI and rolled out it policies. “When AI arrived, I don’t think anybody grasped


how big it would become. We had to quickly adapt internally and come up with policies and consistency in that space. Te consistency is the key to the policy. Tere are always holdouts and siloes, but that was broken really quickly. Everyone knew we couldn’t have separate systems anymore so we collapsed all those silos. We enabled a single platform. “You have to take a reasonable approach, but if


you’re relying on conversations or having to email somebody when you don’t have a strict policy in place, that’s where the biggest problems happen. For example, if we have a meeting and walk away and ask people what the meeting was about, everybody might have a different view. The single platform greatly enabled consistency in our processes. You’re not going to get them right on day one, but you will iteratively make them better and it’s going to be less


niri.org/ irupdate


the pitfalls, and those are important and worthy of consideration. But the reason people are thinking about AI is because there is a lot of opportunity here. AI can enrich the IR function in many ways. “Think about how you want to use AI and the


ways it’s going to help you, and then you can have a framework that’s custom-tailored to that. Tis allows you to implement protections for those specific uses. “Tis new technology is going to evolve. Te SEC


recognizes that AI has value and that people are go- ing to use it. Tey are aware that it’s imperfect, so I think the SEC will try to focus on people’s processes, controls and procedures. If something goes wrong you can admit the mistake and point to the process for handling it.” Eliuk added, “Make sure you have the means to


update your policies and processes. Why? AI regula- tions are forming in 18 states, and eventually it will probably be 50 states, with likely loose policies at the federal level. When you’re working with people and high-risk situations, it’s going to elevate your risk posture. Make sure you document things and have the right metadata behind the scenes so you can continuously monitor and adapt your program as the regulations change.” Elliott noted that AI might be viewed as just another compliance issue that IR professionals are skilled at handling. “Tere’s a lot of truth to that,” Williams said. “IR


professionals have always been concerned about disclosure and accuracy, and that’s really what this is about. Te SEC may gradually issue more prescrip- tive requirements about how AI is used. But we’re far away from that. It has happened a bit in the invest- ment advisor and broker/dealer space about what they can do with predictive data analytics, which is a broad term that includes AI. But for public com- panies outside that context, it is really about disclo- sure and many of the longstanding issues and just applying it to the context of AI.” IR


Al Rickard, CAE, is Editor of IR Update; arickard@ associationvision.com.


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