AI Governance Foundations

1

What AI Is, and What It Is Not

How these systems actually behave

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Artificial intelligence, in the forms this policy governs, produces output by predicting likely content from patterns in the data it was trained on. Unless it is connected to a live source, it is not looking anything up, and it has no way to check what it produces against a source of truth.

Fluency is not accuracy. A wrong answer arrives sounding exactly like a right one, and the system gives no signal that anything is off. This is how these tools behave normally. It is not a fault or a sign that something has gone wrong.

No memory of us

An AI system knows nothing about the Company, our fleet, or our procedures unless someone puts that information in front of it. The Company is building a regulatory assistant with our manuals, procedures, and company context loaded in, which narrows this gap for the work it covers. Until then, and outside it, assume the tool knows nothing about us.

It fills gaps

Where information is missing, the system supplies plausible content in its place. Plausible is not the same as correct.

Correction does not stick

Correcting a system improves that conversation and does not carry forward to the next one.

Output quality follows input quality. General instructions produce general output. Specific instructions, real context, and a clear statement of what correct looks like produce something usable.

Why this matters: these characteristics are the entire reason the Human Ownership Standard exists. An AI system cannot verify its own output, so a named person does. AI Policy §1.1§10.2

2

Recognizing AI Threats

Deepfakes, phishing, prompt injection, social engineering

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Threat 1

Deepfakes and synthetic media

Convincing fake audio and video of a real person can be built from a short public sample. An urgent voice or video request to move money, release information, or skip a procedure is treated as unverified until you confirm it through a channel you start, using contact details you already hold.

Threat 2

AI-generated phishing

AI has removed the spelling and phrasing errors that used to make phishing obvious. Well-written no longer means legitimate. Verify the sender, not the writing.

Threat 3

Prompt injection

Instructions can be hidden inside content an AI reads: a web page, a PDF, an email, a document someone sends you. The tool may act on them as though you had given them. The exposure is greatest for tools that browse, read attachments, or act on your behalf.

Threat 4

Social engineering of the AI

A request framed as a test, an emergency, or an authorized exception can produce output the requester was never entitled to. Authorization comes from this policy and the Approved Tool Registry, never from what a prompt claims.

Never call back on a number supplied in the request. Use contact details you already have. A convincing voice is not verification.

Submit a safety report for any of the four. A deepfake or AI-enabled fraud attempt is reportable whether or not it succeeded. AI Policy §10.2§12.4

3

The Human Ownership Standard

Also known as No AI Slop

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The Human Ownership Standard, also referred to as No AI Slop, is the standard this policy applies to every AI-assisted output. Artificial intelligence is a tool, and the individual who uses it is accountable for the result.

Any output produced with AI assistance that carries your name, your team's name, or the Company's name belongs to you, not to the AI system. Output that has not been read, understood, and confirmed accurate is not ready for use.

Sending, publishing, filing, or acting on unreviewed AI output is a violation of this policy. This applies regardless of how the output was generated, which tool produced it, or the time pressure involved.

Ownership of AI-assisted work requires all five of the following:

Read the output in full, not a summary or excerpt.
Independently verify material factual claims.
Edit the output to reflect the Company's voice and the facts as known.
Remove anything that cannot be verified or is not yours to stand behind.
Be able to defend the output if questioned: understanding what it does and why, verifying it behaves as intended, and accepting accountability for the outcome.

Full professional accountability applies to AI-assisted work exactly as it applies to work produced without AI. AI Policy §1.1

4

What the Policy Covers

Scope, exclusions, and the six guiding principles

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Covered people. All employees of the Company in every department, including leadership. All contractors, consultants, temporary workers, and agents performing work on behalf of the Company. All third parties who access organizational systems or data while providing services.

Covered systems. Generative AI producing text, images, code, audio, or video. Agentic AI taking autonomous actions. Analytical and decision-support AI embedded in software platforms. AI features within approved applications. Custom or internally developed models.

Not covered: standard spell-check and grammar correction, rule-based automation with no machine learning, and vendor-operated AI where no organizational data is processed and no organizational output is involved. The Human Ownership Standard still applies to everything.

Six principles govern any situation the policy does not explicitly address:

Principle	What it requires
Human ownership	Every AI output that represents or affects the organization has a named human owner before use.
Least privilege	AI gets the minimum access needed for the specific approved task.
Transparency	Disclose AI use where the policy, a contract, a regulation, or professional expectation requires it.
Proportionate risk	Controls match risk. Low-risk use gets light oversight; high-risk use gets rigorous review.
Continuous oversight	Approval today is not approval forever. Tools and access are reviewed on a set cadence.
No silent agents	Autonomous action requires documented authorization, defined scope, logging, and human interrupt.

AI Policy §1.3§1.4§2

5

Approved Tools and the Registry

What you may use, and how to get something added

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An unapproved AI tool may not be used for organizational work. This applies regardless of the tool's cost, general availability, or how low the risk appears.

An unapproved tool is any AI tool or AI-powered feature not currently listed in the Approved Tool Registry.

AI features newly switched on inside software the Company already approved require separate review. Approving the software was not approving the feature.

Approval is per use case, not per tool. Being cleared to draft marketing copy in a tool is not clearance to process customer financial data in that same tool. A new use case requires a new intake submission.

Check the registry before using any AI tool for organizational work. Any employee may submit a tool for vetting through the AI Tool Intake Form, which routes to the CISO for a risk-tier determination.

Risk tier	Decision timeline	Note
Tier 1	Within 5 business days	Decisions are issued in writing.
Tier 2	Within 15 business days	Approved tools reach the registry within 5 business days.
Tier 3	Within 30 business days	Agentic capability is automatically Tier 3.

Amnesty window. During the window you may disclose a tool you are already using with no disciplinary consequence. Disclosed tools simply enter the vetting queue. After the window closes, use of unapproved tools falls under the consequence framework. AI Policy §4§5

6

What AI May and May Not Touch

The Non-Supersession Rule and system access defaults

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The Non-Supersession Rule. An AI system will never hold, exercise, or be granted access permissions exceeding those of the authorized human user. The security posture of the underlying system is the ceiling for any AI interaction with it, not the floor. This rule is absolute, and no exception is ever granted to it.

An AI tool operating under your credentials cannot reach systems, files, or data you are not personally authorized to access.
Granting an AI system elevated permissions to work around a workflow inconvenience is a policy violation.
When your access changes through promotion, role change, or departure, your AI access is adjusted at the same time.
Shared or service-account AI access is prohibited without written CISO approval.

Default AI access by system. Variation from these defaults requires written approval from the CISO.

System	Default access	Key condition
FOS	Read + draft	No automatic release of flights. A human reviews and executes all scheduling and dispatch actions.
Financial systems	Read + draft	Write access requires President and CFO written approval. No AI-initiated transactions.
HR and people systems	Read only	AI may not modify compensation, titles, employment status, or performance records.
Code repositories	AI-assisted	Human commit required. No autonomous merge or deploy.
Email and messaging	Draft only	No automatic send. Sending requires explicit human action.
External-facing content	Draft only	Full human review and approval before publication.
Customer and passenger data	Scoped read	Limited to approved fields. Governed by data classification and TSA SSI handling rules.
Identity and access management	Read only	AI may not provision, modify, or revoke user access under any circumstances.
Payment and transaction systems	Prohibited	No access without explicit AI Steering Committee approval.

AI Policy §6.1§6.4

7

Personal Use and Company Seats

Where your own AI use ends and the Company's begins

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Use AI freely in your personal life, on personal devices and personal accounts, for any purpose unrelated to Company business. No approval, oversight, or disclosure is required. That freedom ends where personal use touches organizational systems, data, or work product.

Four hard boundaries. These apply regardless of whose device or account is involved.

Nothing unapproved on Company equipment. If it is not in the Approved Tool Registry, do not install it, sign into it, or open it on a Company laptop, phone, account, or network. This holds even when what you are doing is personal.
No Company data in a personal account. Client information, passenger information, anything confidential: it does not go into your own AI account or into an unapproved tool. Your kitchen table counts the same as your desk.
No Company work on a personal tool. Not drafts, not analysis, not code. Moving the finished output into an approved tool afterward does not fix it, because the data already left.
Personal output is not Company work product. Something you made on your own account for your own purposes does not get submitted, forwarded, or folded into a Company deliverable.

If you are unsure whether a specific use qualifies as personal, treat it as organizational and apply the approval requirement.

Company-provisioned seats. If the Company pays for your individual seat, occasional personal use is permitted provided it does not interfere with job performance. The account is Company property. The Company can access content created under it where there is a compliance, legal, or investigative need, so treat anything you enter there as Company records rather than private. Your own personal account is separate and is not covered by that. The seat may not be used for outside commercial purposes, including a side business, freelance work, or work for another employer, and access ends immediately on termination. AI Policy §6.6§6.7

8

Review, Disclosure, and Reporting

Minimum standards, when to disclose, and how to report

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Different output types carry different minimum review standards. These supplement, and do not replace, the Human Ownership Standard.

Output type	Minimum review
External communications	Full read and edit by the named sender, who executes the send personally.
Legal or contractual documents	Full review plus legal sign-off. Attorney review for anything legally binding.
Financial analyses and reports	Full review plus numerical verification, with written attestation on file.
Code and technical artifacts	Tested before use, by a person who can confirm it does what it is supposed to do. No AI-driven deploy, and nothing goes live without a person choosing to put it there.
Regulatory and compliance filings	Full review plus sign-off by the accountable manager for that filing.
Presentations and board materials	Full review by the presenter, who is accountable for every claim.

No AI-only submission to the FAA, TSA, or any regulator under any circumstances.

Disclosure is required for external documents submitted to regulators, courts, or government agencies including the FAA and TSA; client-facing deliverables where the engagement agreement specifies it; published content where platform or industry rules require it; and internal communications where a material business decision rests on AI-generated analysis.

Standard disclosure language: "This was prepared with AI assistance and reviewed and approved by [NAME], [TITLE]."

Reporting. Submit a safety report, the same way you would for any other safety event. Anonymous and confidential options are both available.

AI-related incidents fall into three categories:

Category A

Data breach or disclosure

An AI-related data breach, or organizational or client data disclosed to somewhere it should not be.

Category B

Hallucination-driven decision

A decision with material business, legal, or safety consequences that was made on the basis of AI output which turned out to be wrong.

Category C

Agent outside its scope

An agentic AI system took an action outside the boundaries set in its approved Action Scope document.

Report this	What happens
Shadow AI use, yours or a colleague's	Triaged by the CISO. During the amnesty window, no disciplinary consequence.
Suspected data exposure through an AI tool	Category A. Triaged by the CISO and Director of Safety within 1 business day.
A hallucination that drove a material decision	Category B. Same channel and triage timeline.
An AI agent acting outside its authorized scope	Category C. Addressed whether or not harm resulted.
A deepfake, AI fraud attempt, or AI phishing	Triaged by the CISO. External Legal engaged where there is legal exposure.

Good-faith reporting is protected. Retaliation against a reporter is a policy violation. AI Policy §7.1§7.2§12.4

Knowledge Check

Acknowledgment