AI Use Policy

This AI Use Policy (Policy) explains how Finflo Pty Ltd (ABN 56 697 541 718) (‘Finflo, we, us or our’) uses artificial intelligence (AI) in the Finflo Platform, what our AI features can and cannot do, and the responsibilities of participants, firms, advisers and users who use them. It applies to every participant and user using the Finflo Platform, whether access is provided to an organisation or to an individual user.

This Policy forms part of, and should be read with our Terms and Privacy Policy. Capitalised terms used but not defined in this Policy have the meaning given to them in our Beta Participation Agreement or other applicable platform terms.

1.HOW FINFLO USES AI

Finflo uses third-party AI services to help Authorised Users work more efficiently. Depending on the features enabled, our AI may assist with:

• drafting documents and advice-related content;
• summarising files, records and meeting transcripts;
• generating file notes and draft summaries;
• document generation and template completion;
• search, retrieval and information look-up;
• workflow suggestions and prompts; and
• preparing draft advice content for adviser review.

2.WHAT FINFLO AI DOES NOT DO

Finflo is software for workflow, data management, drafting, modelling and document generation. Finflo is not an Australian financial services licensee, authorised representative, financial adviser, tax agent, accountant, lawyer, auditor or compliance consultant. Our AI features do not:

• provide financial advice or approve advice;
• replace the judgment of a qualified and authorised Adviser;
• independently verify Client information, facts or assumptions;
• guarantee the accuracy, completeness or currency of any output;
• make final advice decisions;
• issue advice to Clients; or
• take action on any matter without explicit user approval.

3.AI OUTPUTS ARE DRAFTS ONLY

AI outputs are drafts to assist Authorised Users. They must not be treated as authoritative merely because they were generated by the platform. AI outputs may be:

• inaccurate, incomplete or outdated;
• biased or inconsistent;
• based on misunderstood instructions;
• unsupported by the underlying source material; or
• plausible but false (including fabricated content, figures or references).

This applies with particular force to draft Statements of Advice, Records of Advice, file notes, summaries, recommendations, strategy content and Client communications, each of which remains a draft until reviewed and approved by an appropriately authorised Adviser.

4.YOUR RESPONSIBILITIES WHEN USING AI

Authorised Users must review and take responsibility for every AI output they use. Before relying on, finalising or issuing any AI-assisted content, an Authorised User must:

• review the AI output in full;
• check it against the source documents and Client facts;
• verify all calculations, figures and assumptions;
• edit or reject any content that is incorrect, unsupported or inappropriate;
• ensure any legal, regulatory, tax and product statements are correct; and
• obtain Adviser approval before any advice is finalised or issued.

5.ADVICE-SPECIFIC SAFEGUARDS

All advice-related AI content is draft only. An appropriately authorised Adviser must review and approve the final advice. The Participant, and where applicable the relevant advice firm, authorising licensee and Adviser, remain responsible for the final advice and the Client outcome.

Finflo does not review, approve or issue financial advice, and AI agents do not take action without explicit user approval.

Finflo may provide approval workflows, warnings and controls designed to support review and approval, but the Participant remains responsible for ensuring that no advice is finalised, saved as a final advice record, downloaded, sent or issued without approval by an appropriately authorised Adviser.

6.HOW AI HANDLES INFORMATION

Where enabled by the Participant or relevant user, AI features may process Client profile information, financial information, documents, meeting transcripts and sensitive information submitted through the platform. The Participant is responsible for having all rights, consents and authority required for that information. Where the Participant is an individual using the Platform in connection with clients of an advice firm or licensee, the Participant must ensure they have all necessary firm, licensee, client and other authority required to use that information with the Platform.

Tax File Numbers (TFNs) must not be submitted to Finflo or included in any AI feature. Authorised Users must review and redact TFNs from source material before uploading it or using it with an AI feature. TFNs may appear incidentally in superannuation, tax, insurance or identity documents, so Authorised Users must check documents before use.

Under our current AI provider arrangements and settings, Customer Data submitted to Finflo's AI providers is not used by those providers to train their models. Further detail on how Finflo handles personal information is set out in the Finflo Privacy Policy.

AUTOMATED DECISION-MAKING

Finflo's AI supports adviser decision-making and workflow. Authorised Users are prompted to check AI content and suggestions, and to approve or reject them, before a draft advice document is finalised.

Finflo does not intend for its AI to make, or substantially contribute to, decisions that significantly affect a person's rights or interests without human review. Finflo's AI features assist Authorised Users and do not make final financial advice decisions.

CHANGES TO THIS POLICY

Finflo may update this Policy from time to time to reflect legal, technical or operational changes. We will make the current version available to Participants and, where relevant, in the Platform/product. Continued use of AI features after an update means the updated Policy applies.

QUESTIONS

If you have any questions about this Policy or how Finflo uses AI, please contact Finflo at support@finflo.au.