Policy on Use of Artificial Intelligence at the MacArthur Foundation

Given the evolving and fast-moving developments in AI and the integration of AI tools across sectors, the Foundation will engage with AI consistent with this policy and in accordance with the following overarching approach and philosophy:

1. A. The Foundation will develop a safe, secure, responsible, and strategic approach to the integration and use of AI in an equitable and holistic manner across the Foundation – balancing the power of AI as an enterprise asset while meeting the individual needs of departments and program areas

2. B. The Foundation will iterate to respond to technological, legal, and other developments to ensure use of AI is consistent with the Foundation’s values.

3. C. The introduction and proposed use of AI tools will be approved through flexible processes that ensure compliance with Foundation policies and the law while allowing departments and programs to pursue new developments and opportunities, recognizing the speed of change.

4. D. AI tools will be evaluated periodically to assess their intended benefits and identify any issues that indicate further use, modification of the use, or cessation of the use.

5. E. The Foundation will responsibly use AI tools in alignment with its values to increase efficiencies and productivity throughout its operations and to reduce burdens to grantees in the grant process, including applications and reporting.

An AI Steering Committee (“AISC”) is hereby established with the roles and responsibilities set forth herein. The AISC may approve a charter consistent with the terms of this policy that will provide additional detail regarding the operations of the AISC.

Membership:

Members of the AISC shall be appointed by the President and are expected to be representative of the departments of the Foundation and at least one program representative. The President shall also appoint a Chair or Co-Chairs of the AISC. The terms of membership and other operational details will be set forth in the charter.

Responsibilities:

The AISC will be responsible for the following regarding AI at the Foundation:

1. (i) Approval and oversight of the use of AI tools in accordance with processes and procedures approved by the AISC in this policy or as subsequently determined and communicated to Staff.

2. (ii) Development of the strategy and philosophy for the overall use of AI by the Foundation and provide enterprise wide guidance on AI use and investment.

3. (iii) Lead and guide the Foundation’s external engagement with the sector on the responsible and ethical use of AI and help position the Foundation as a credible leader in the responsible use of AI.

4. (iv) Ensure alignment with the Foundation’s values and mission, risk tolerance, strategic priorities, and work.

5. (v) Ensure coordination across departments and programs for responsible, strategic, and fiscally sound AI use.

6. (vi) Monitor developments relating to AI in the philanthropic, private, and public sectors and report periodically back to the President and the Leadership Advisory Team.

The AISC will not have any authority, responsibility, or engagement in programmatic strategy and grantmaking activities of the Foundation, except to serve as a resource, as appropriate and when helpful.

AI Learning Resource Network (AILRN)

The AISC will oversee the establishment of the AILRN that will include representatives of departments and programs designated by the heads of departments and programs. The AILRN is expected to engage in a range of activities to be more specifically identified in a guidance document crafted by the AISC with input from interested Staff. Activities may include one or more of the following and others as approved:

1. A. Establish and maintain a use library of AI tools and learnings

2. B. Facilitate the identification of AI-related learning needs

3. C. Help design and facilitate learning opportunities, in partnership with People & Culture (P&C) and IT

4. D. Curate and maintain use case libraries

The following principles and required steps will guide the use of AI tools at the Foundation:

A. Use Only Permitted AI Tools

• Authorized AI tools. The AISC will maintain and make available to Staff a list of authorized AI tools and Prohibited AI tools and update the lists, as necessary.

• Suggested use. Any program or department wishing to use an AI tool that has not previously been approved may suggest to the AISC the use of an AI tool together with an analysis of the AI checklist in Appendix 2. The IT and Legal Department will review the proposed use, including the terms of service, and any intellectual property, privacy, and security uses and, if approved, the tool will be added to the authorized AI tool list and be shared with the AISC.

• When to download. Approved tools may be downloaded for use, provided Staff are utilizing a Foundation-provided license with multi-factor authentication enabled.

• Registering for tools. Only register (if applicable) and use tools under your Foundation or business email address (i.e., do not conduct Foundation business using a personal email address or account).

• Embedded AI tools. AI tools embedded in productivity programs or platforms such as Zoom, Teams, Workday or similar technology platforms, that require a user to opt in to the functionality (such as AI notetaking and similar tools) should not be used unless the embedded tool has been approved by the IT Department in consultation with the Legal Department and the requirements for such use have been developed. In that regard, using AI functionality embedded in approved platforms (e.g., Zoom, Microsoft Teams) may be permitted for notetaking, transcription, and summary purposes only under the following conditions:

  • The host of the internal MacArthur meeting must follow the procedures approved by the Foundation for the recording of Zoom or Teams calls which requires, among other things, notice in advance that such tool(s) will be used for the meeting and a reminder at the start of the meeting that the embedded tool will be used. In both cases, the meeting host must allow participants to decline to participate in the meeting or request that such a tool not be used.

  • The approved embedded tools should not be used during in-person or virtual meetings in which it is anticipated that Legal Counsel will be providing legal advice.

  • All summaries, notes, or transcripts will not be distributed outside the Foundation and will be stored only temporarily in accordance with the Foundation’s Record Information Management Policy.

  • The limitations described herein do not apply to the use of closed captioning.

• External meetings hosted by MacArthur. Staff should not trigger the use of embedded AI tools such as notetaking, summaries, or transcripts without notice to and the consent of other participants to the meeting. If consent is unclear, the tool should not be used except in consultation with the Legal Department.

• External meetings hosted by third parties. Staff should be aware of instances in which a third-party host has triggered the use of embedded AI tools for a meeting in which MacArthur Staff are participating. Depending on the nature and sensitivity of the meeting (and other circumstances such as the number of attendees), Staff should request that the host disable the use by requesting the following or similar words: “Under MacArthur’s policy on the use of Artificial Intelligence in meetings, I request that the [AI summary, notetaker] be disabled.” This would especially be the case where the subject matter may be sensitive, involve confidential information, or where it is not clear how the resulting product may be used or stored. If the host will not abide by the request, the Staff member should consider leaving the meeting, but departure is not required if the Staff member concludes their presence is necessary for business purposes.

B. Protect Confidential Information¹and Maintain and Uphold Security and Privacy

• Do not include (or upload) any confidential, proprietary, personal, or sensitive information of the Foundation, grantees, vendors, investees, or others with whom we engage in any queries, prompts, or inputs to AI tools except as permitted by this policy.

• Do not download any AI technology to a Foundation device (laptop, phone) or the Foundation’s network unless it is an approved AI tool or with documented permission of the IT Department.

• Appendix 1 describes categories of data based on its sensitivity and confidentiality and the permitted use of such data in the AI tool indicated.

• For approved tools: If using an approved tool, follow all security and privacy safeguards required by the Foundation.

• For prohibited tools: Refrain from using these tools in the course of Foundation-related work, regardless of whether data is public, non-sensitive, or confidential.

• For public tools (neither prohibited, nor approved for enterprise use): Only publicly available data may be used in these tools unless the AISC has reviewed and authorized specific tools as provided herein.

C. Be Transparent and Disclose Use

• If Staff use an AI tool for Foundation work and it is material to the final work product, you should disclose that the work product was based in part on information gleaned from an AI tool.

• AI-generated content does not need to be disclosed for everyday minor tasks (e.g., grammar suggestions, brainstorming) when using tools that are approved for use at the Foundation.

• Disclosure is required when:

  • AI is a primary contributor to the final written work product or responsible for a majority of the final content.

  • AI is used to generate media, including images, audio, or video.

• How to disclose:

  • If AI was a primary contributor to written material, include a general statement in the document: “This product was generated using [AI tool] and reviewed for accuracy and completeness.”

  • In the case of AI-generated media, a watermark must be added to indicate, “Generated by AI.”

  • If unsure whether disclosure is needed, consult the Legal Department

D. Understand That You Are Responsible for the Accuracy of Content Generated by AI and It Should Be Used Consistent with Our Values

• Information from AI tools may not be accurate, may be offensive, may reflect racial, gender, or other biases because of where the underlying information is drawn from and may not be consistent with our values.

• Use caution when using AI tools that might limit fairness and inclusion, such as in recruiting processes or in selecting vendors or investment managers. AI tools should only be used to help inform decision making, as helpful, but not to make decisions about recruiting, hiring, or selecting vendors.

• Ensure AI usage serves essential functions or provides tangible benefits. Be aware that AI tools can result in a significant carbon footprint connected to the electricity and computing resources needed to run the servers powering AI modeling tools.

• Be Responsible:

  • Do not use AI content verbatim and do not rely exclusively on an AI tool generated product if you are producing a written document for the Foundation or public consumption. Always check your work and sources.

  • You are responsible for reviewing, fact-checking, and ensuring accuracy before using AI-generated results in Foundation work.

  • AI should assist, not replace, human authorship. Avoid relying upon AI-generated content without review or edits.

  • When using AI, cross-check outputs with trusted sources before distributing any information internally or externally.

E. Respect Copyrights and Other Intellectual Property

• Do not use AI tools for generic outputs that might result in raising questions of copyright because they are similar to or based on known works of art or other copyrightable materials (e.g., do not ask the AI tools to make a modification of a known work, author, or character, real or imaginary, such as make a picture of Barbie as an astronaut).

• Any questions regarding the use of AI tools that might raise copyright issues should be directed to the Legal Department.

F. Use Approved AI Tools in Ways that Increase Productivity

• AI can be a helpful tool when used appropriately.

• AI use cases for the Foundation include but are not limited to:

  • Creating initial drafts of emails, reports, or summaries that are carefully reviewed and deeply edited.

  • Using AI to generate ideas, outlines, or refine existing concepts.

  • Identifying trends or summarizing large datasets (adhering to guidance on personal/sensitive data in section 2, “Handling Confidential and Sensitive Data”).

  • AI translation tools may be used for internal purposes only (not for legal documents or contracts).

  • AI tools embedded in approved platforms (e.g., Zoom, Teams) may be used for notetaking and summaries only as permitted by this Policy.

• The following are NOT acceptable uses of AI:

  • Generating final work products without human review.

  • Using AI for hiring decisions or personnel evaluations.

  • Using AI for grantmaking decisions or evaluation.

  • Relying on AI for legal or financial guidance.

  • Modifying copyrighted materials such as a known work, author, or character, real or imaginary.

G. Staff Input and Engagement is Encouraged and Staff Should Share Best Practices and Results

• Staff are encouraged to participate in discussions regarding possible AI tools and to provide feedback and ideas on how AI tools can be leveraged to improve our work and the organization.

• If you find (or imagine) a use of AI tools that you think would be particularly useful for the Foundation in our work, please let AILRN know with a brief explanation of the use and its benefits and the AILRN will maintain an AI Ideas Bank and report use periodically to the AISC.

1. 1. Please see our Employee Handbook to review applicable policies, including confidentiality obligations as an employee. Please contact Legal if you have questions about the definition of confidential and/or sensitive information or how the information you enter can be used by an AI tool.

The use of AI tools by third parties engaged by the Foundation, including consultants, vendors, and grantees can have implications for and potential liability to the Foundation. To balance the business needs of third parties while protecting the Foundation’s interests, agreements with third parties (except for general operating support grants), the Legal Department will include appropriate language, whenever practical, that will recognize the evolving legal and business environment and will seek to include terms as applicable to the circumstances and identity of the third party based on the following principles:

1. A. Disclose to the Foundation use of AI tools when AI is a primary contributor to the final work product provided to the Foundation or produced with funding provided by the Foundation for the specific work product and is made publicly available, or AI is used to generate media, including images, audio, or video.

2. B. Represent that work product produced under the applicable agreement with an AI tool and provided to the Foundation or made publicly available does not violate copyright or other intellectual property rights.

3. C. To the extent the Foundation may in the future make grants to support the production of an AI tool, the grant agreement will include specific provisions consistent with the principles of this Policy.

If you notice unexpected behavior, bias, or ethical concerns with an AI tool, report them to the AISC.

The AISC will review the Policy every six months and any suggested changes reviewed by the IPC at least annually. 

Adopted: December 18 2023

Revision History:

• June 2, 2025: Policy on Use of Artificial Intelligence at the MacArthur Foundation includes updates to the Policy, additional Appendices, and some formatting.

• July 2026

Policy Authority: Institutional Policy Committee

Reviewed and approved by IPC on September 23, 2026 with review period added

Policy Maintained by: Office of the General Counsel