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Artificial Intelligence Usage & Governance Policy

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Reyyan Turan
Reyyan Turan
Written on March 17, 2026 Updated on March 17, 2026

Last Updated: March 2026

This Artificial Intelligence Usage & Governance Policy (“Policy”) governs the design, deployment, access, and use of artificial intelligence functionalities made available through the Search Fund Plus platform (“Platform”).

By accessing or using any AI-enabled features of the Platform, the User agrees to comply with this Policy.

1. Purpose and Scope

Search Fund Plus integrates artificial intelligence systems (“AI Systems”) to support data-driven decision-making, operational efficiency, and analytical augmentation within the search fund lifecycle.

AI Systems are designed to assist—not replace—human judgment and:

  • Do not constitute investment advice, legal advice, financial advisory, tax advice, or valuation services;
  • Do not create fiduciary duties on the part of Search Fund Plus;
  • Do not eliminate the User’s obligation to conduct independent due diligence.

All decisions relating to acquisitions, investments, outreach, negotiations, and contractual commitments remain solely under the User’s authority and responsibility.

2. AI Governance Framework

Search Fund Plus adopts a risk-based AI governance model aligned with international best practices.

AI use cases are categorized as:

  • Low-Risk: Data structuring, enrichment, workflow automation
  • Moderate-Risk: Scoring models, prioritization, analytics insights
  • High-Risk: Any output influencing investment decisions, valuation, or external representations

Enhanced human oversight, validation, and documentation requirements apply to moderate and high-risk use cases.

3. Permitted Use of AI Systems

AI Systems may be used exclusively for:

  • Target screening and prioritization
  • Data enrichment and normalization
  • Pipeline analytics and performance monitoring
  • Fit Scoring™ calculations
  • Pattern recognition across datasets
  • Operational and workflow optimization insights

Users shall not rely on AI outputs as the sole basis for:

4. Human Oversight and Accountability

Search Fund Plus operates under a Human-in-the-Loop (HITL) governance framework.

All AI-generated outputs, including but not limited to:

  • Risk indicators
  • Target scoring outputs
  • Ranking or prioritization results
  • Predictive insights
  • Outreach recommendations

must be:

  • Independently reviewed
  • Contextually validated
  • Approved by a qualified decision-maker

before any operational, financial, or strategic reliance.

The User remains fully accountable for all decisions taken.

5. Data Governance and Responsibility

The User represents and warrants that:

  • All uploaded data is lawfully obtained and processed
  • The User has legal authority to use such data
  • Submitted information is accurate, complete, and not misleading

Search Fund Plus:

  • Does not verify all user-provided data
  • Is not responsible for errors resulting from inaccurate inputs
  • Relies on data integrity for AI output quality

AI outputs are inherently dependent on input data accuracy.

6. Model Limitations, Bias, and Risk Disclosure

Users acknowledge that AI Systems:

  • May generate false positives or false negatives
  • May reflect statistical bias or incomplete datasets
  • May not capture qualitative, behavioral, or market-specific nuances
  • Are probabilistic, not deterministic

Search Fund Plus does not guarantee:

  • Accuracy of predictions
  • Completeness of insights
  • Absence of bias

Users are required to apply independent judgment and critical evaluation at all times.

7. Third-Party AI and Infrastructure

Search Fund Plus may utilize third-party AI providers or infrastructure components.

In such cases:

  • Confidential data is not used to train public or shared models
  • Data processing is subject to contractual safeguards and confidentiality obligations
  • Where feasible, data minimization and anonymization techniques are applied

Users acknowledge that certain AI functionalities may depend on external systems beyond the direct control of Search Fund Plus.

8. Security, Confidentiality, and Data Protection

Search Fund Plus implements appropriate technical and organizational measures to ensure data security, including:

  • Access controls and authentication mechanisms
  • Data segregation and encryption protocols
  • Monitoring and anomaly detection systems

All processing activities are conducted in accordance with:

  • Applicable data protection laws, including KVKK (Law No. 6698)
  • Where applicable, the General Data Protection Regulation (GDPR)

9. Prohibited Conduct

Users shall not:

  • Manipulate or attempt to distort scoring algorithms
  • Upload fraudulent, fabricated, or misleading data
  • Reverse-engineer, decompile, or extract AI logic
  • Use AI outputs to mislead investors or third parties
  • Circumvent human review requirements
  • Use AI Systems for unlawful or unethical purposes

Violation of this section may result in immediate suspension or termination of access.

10. Audit, Logging, and Monitoring

Search Fund Plus reserves the right to:

  • Log and monitor AI usage activity
  • Audit system interactions for compliance and security purposes
  • Investigate misuse, anomalies, or suspicious behavior

Such monitoring is conducted in accordance with applicable laws and internal compliance policies.

11. Incident Management and Reporting

In the event of:

  • Material AI errors
  • Data breaches or unauthorized access
  • Misuse of AI Systems
  • Significant model malfunction

Search Fund Plus may:

  • Suspend affected functionalities
  • Notify impacted users where required
  • Implement corrective or mitigating measures

Users are expected to promptly report any suspected issues.

12. No Guarantee of Outcomes

Search Fund Plus makes no representations or warranties regarding:

  • Deal sourcing success
  • Investment performance or returns
  • Transaction completion
  • Outreach effectiveness
  • Predictive model accuracy

All AI functionalities are provided on an “as is” and “as available” basis.

13. Intellectual Property

All AI-related components—including:

  • Algorithms
  • Scoring methodologies
  • Models
  • System architecture
  • Analytical frameworks

constitute the exclusive intellectual property of Search Fund Plus.

No rights are transferred to Users except for limited use within the Platform.

14. Limitation of Liability

To the fullest extent permitted by applicable law, Search Fund Plus shall not be liable for:

  • Indirect, incidental, or consequential damages
  • Investment or financial losses
  • Errors in AI outputs or predictions
  • Decisions made based on AI-generated insights

Users retain full responsibility for independent analysis and due diligence.

15. Amendments

Search Fund Plus reserves the right to amend this Policy at any time.

Continued use of the Platform constitutes acceptance of the updated Policy.

16. Governing Law

This Policy shall be governed by and construed in accordance with the laws of Türkiye, without regard to conflict of law principles.

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