Recording Notice and Generative AI Use Policy for Non-ICI Staff

Recording Notice and Generative AI Use Policy for Non-ICI Staff

1. Purpose

This policy outlines the Investment Company Institute’s (“ICI”) position on the use of recording devices, AI-enabled devices and software, and Generative Artificial Intelligence (“GenAI”) tools by non-ICI staff during ICI Board, Committee, and other meetings.
 

2. Scope

This policy applies to all non-ICI staff who attend meetings organized by ICI. Examples include, but are not limited to, members of the ICI Board of Governors, ICI committee members (including those on advisory groups, task forces, and working groups), independent directors, consultants, guest speakers, external advisors, invited guests or observers, and volunteers participating in ICI initiatives.

3. Prohibited Use

Non-ICI staff are strictly prohibited from using recording devices, AI-enabled devices and software, or GenAI tools—such as ChatGPT, Copilot, Gemini, and similar technologies—during ICI hosted meetings to record, transcribe, summarize, or analyze meeting content. This prohibition applies regardless of whether the devices or technologies are visible or concealed. In limited cases, ICI may provide explicit prior written consent to allow recording or AI-assisted functionality. Such exceptions must be approved in advance of the meeting, documented by the meeting organizer, and consented to by the other participants of the call.
 

4. Confidentiality and Legal Considerations

Many jurisdictions prohibit the recording of conversations without consent. The use of GenAI tools to record or process meeting content may result in the unauthorized distribution of confidential information, posing legal and reputational risks to ICI and its members.
 

5. Enforcement

Violations of this policy may result in removal from the meeting and revocation of future participation privileges. ICI reserves the right to take additional action as necessary to protect its confidential information.
 

6. Acknowledgment

All non-ICI staff covered by this policy must acknowledge receipt and understanding of this policy—via a platform-based acknowledgment—prior to participating in ICI hosted meetings.
 

7. Administration

This policy is administered by ICI’s Chief Information Officer (CIO) and Chief Information Security Officer (CISO) in coordination with the Chief Operating Officer (COO). ICI reserves the right to modify this policy at any time.
 

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