Artificial Intelligence Ethics Policy

1. Purpose

The purpose of this AI Ethics Policy is to guide Xcel Property Media, LLC in the development, deployment, and use of Artificial Intelligence (AI) technologies in an ethical and responsible manner. This policy outlines the principles that the company and its employees will follow to ensure that AI systems are designed and used in a way that respects human rights, promotes fairness, and enhances the well-being of all stakeholders.

2. Scope

This policy applies to all employees, contractors, and partners of Xcel Property Media, LLC involved in the research, development, deployment, and use of AI technologies.

3. Policy

3.1. Respect for Human Rights Xcel Property Media, LLC is committed to respecting and upholding human rights in all its AI-related activities. AI systems will be designed and used in a way that respects the rights to privacy, non-discrimination, and freedom of expression, among others.

3.2. Fairness and Non-Discrimination Xcel Property Media, LLC will actively work to identify and mitigate biases in AI systems, ensuring that they do not perpetuate or exacerbate existing inequalities.

3.3. Privacy and Data Protection Xcel Property Media, LLC will prioritize the privacy and data protection of individuals when designing and using AI systems. The company will comply with all applicable data protection and privacy laws and adhere to industry best practices for data handling and storage.        

3.4. Transparency and Explainability AI systems used by Xcel Property Media, LLC will be transparent in their operation, and the company will  provide clear explanations of the logic and reasoning behind AI- generated outputs. Xcel Property Media, LLC will maintain a centralized system for AI governance and compliance efforts.

3.4.1. AI Edit Disclosure Classification

To make Section 3.4 consistently applicable, Xcel Property Media, LLC classifies AI-assisted image and video edits into two tiers based on whether the edit changes the depicted state of the property, not merely on whether AI was used.

Tier 1 – No disclosure required. Cosmetic or atmospheric adjustments that do not alter the property's actual features, condition, or functionality. This includes sky replacement, color and exposure correction, HDR blending, the addition of subtle ambient motion (e.g., moving clouds, rippling water) that does not imply a functional feature that does not exist, incidental clutter removal (e.g., garden hoses, trash cans, personal items, vehicles) that does not reflect on the property's condition or features, and brightness/exposure adjustments to lighting that was actually on at the time of capture (including HDR blending of interior and exterior light). This classification will be reassessed under Section 4.4 (Periodic Reviews) as state law and MLS disclosure standards for AI-assisted editing continue to develop.

Tier 2 – Disclosure required. Edits that alter the depicted state of the property or imply a feature, condition, or function that does not exist. This includes virtual staging, removal or addition of physical objects or defects, structural or landscaping alterations, seasonal or condition-based landscaping enhancement (e.g., greening dormant or brown grass, removing snow, adding leaves or bloom), motion effects that suggest working systems (e.g., flowing fountains, operating fireplaces) that are not actually functional, and digitally adding light that was not present at capture (e.g., illuminating fixtures or windows that were off, or day-to-dusk/twilight conversion depicting a lighting condition and time of day that did not exist when the photo was taken). Tier 2 edits must be clearly labeled as AI-assisted or virtually altered in any listing, marketing material, or client deliverable in which they appear.

Additional Tier 1 examples. Color/clarity adjustment of pool water that is actually present; incidental interior clutter removal (e.g., laundry, dishes, personal items) that does not indicate a defect; and lens distortion or perspective correction that restores accurate proportions without exaggerating room dimensions or scale.

Additional Tier 2 examples. Adding water to an empty or drained pool, or removing algae/debris from pool water; removal of dead or overgrown landscaping such as weeds, dead shrubs, or bare patches (treated the same as the seasonal landscaping condition edits above); removal of visible interior defects such as water stains, cracks, or mold; and any digital alteration that exaggerates room dimensions or scale beyond correcting for lens distortion. These edits require the same disclosure treatment as other Tier 2 edits above.

Disclosure handoff to listing agents. Xcel Property Media, LLC does not control the MLS or marketing platforms on which its client-facing agents publish photos. Xcel's disclosure obligation under this section is to deliver, with every Tier 2 edit, the appropriate disclosure caption/label language and, where applicable, a watermarked version of the image. Applying that disclosure within the MLS listing, brokerage website, or other marketing platform is the responsibility of the listing agent or client to whom the deliverable is provided. Xcel will document in each delivery which images are Tier 2 and provide ready-to-use disclosure text so clients can comply with their own MLS and brokerage requirements.

Disclosure format: badge and caption. Every Tier 2 image will carry a two-part disclosure: (1) a badge embedded directly in the image, sized and placed to be readily noticeable at normal viewing size (comparable in visibility to a standard photo-credit watermark) without obscuring the property, positioned consistently in a corner of the frame; and (2) a specific disclosure caption identifying the nature of the edit (e.g., "Lawn color digitally enhanced," "Virtually staged," "Sky/lighting altered"), added to the photo caption and/or listing remarks provided to the client. The badge signals that an edit was made; the caption states what it was. Neither element alone satisfies this policy's disclosure requirement.

Recordkeeping. Because an embedded badge may not survive resizing, cropping, screenshotting, or resyndication once an image leaves Xcel's control, Xcel will retain the pre-edit original of every Tier 2 image, along with a record of the disclosure applied, for a minimum of three years from the date of delivery, and will make the original available on request. This recordkeeping is Xcel's independent audit trail of compliance and does not depend on the badge or caption remaining intact on any copy of the image found elsewhere.

No removal of Tier 2 disclosure. Xcel Property Media, LLC will not remove, suppress, or omit the required badge or caption disclosure from a Tier 2 edit at a client's request. If a client does not want a property depicted with a Tier 2-level alteration, the alternative is to not perform that edit, not to perform it undisclosed. This applies regardless of client preference, deadline pressure, or competitive concerns. The agent can replace a Tier 2 image with a Tier 1 image if available.

3.5. Accountability and Responsibility The Xcel property Media, LLC  CEO or designate is responsible for ensuring that AI technologies align with this policy and for addressing any adverse impacts resulting from their use.

3.6. Safety and Security AI systems will be designed, developed, and used with a focus on safety and security. Xcel Property Media, LLC will prioritize the protection of customers’ potential harm and will work to minimize risks associated with AI technologies.

3.7. Human-Centered AI AI systems will be designed to augment and empower human decision-making, not replace it.  Xcel Property Media, LLC will promote human-AI collaboration and ensure that humans retain control over AI systems and their outputs.

3.8. Environmental and Social Sustainability Xcel Property Media, LLC will strive to use AI technologies in a manner that promotes environmental and social sustainability, minimizing negative impacts on the environment and communities.

4. Implementation and Monitoring

4.1. AI Ethics Implementation Responsibilities The Xcel Property Media, LLC CEO or designate is responsible for overseeing the implementation of this policy, providing guidance on ethical AI practices, and monitoring the company's AI-related activities for compliance with these principles.    

4.2. Training and Education Xcel Property Media, LLC is committed to the research, development, deployment, and  ethical use of AI technologies.   The principles outlined in this policy will be disseminated throughout all aspects of the company.

4.3. Collaboration and Engagement Xcel Property Media, LLC will actively engage with employees, customers, partners, and regulators, to promote dialogue, share knowledge, and collaborate on ethical AI practices.

4.4. Periodic Reviews Xcel Property Media, LLC will conduct periodic reviews of the company's AI-related activities to ensure adherence to this policy, identify emerging ethical risks, and make updates to the policy as necessary.

5. Enforcement

Xcel Property Media, LLC employee violations of this policy will result in disciplinary action

Revisions: 3.4.1. AI Edit Disclosure Classification added 9/16/26