Contents
1Purpose
This Policy defines the environmental, social and governance (ESG) principles that govern how AryAI designs, builds, governs and operates enterprise AI infrastructure and AI governance platforms, and how we conduct ourselves as a business.
It exists to ensure that every AI factory we deliver, every NYAYA platform we build and every programme we run is specified, measured and evidenced against ESG criteria from the first design review to final handover — and that our clients, partners, regulators and people can rely on that evidence.
2Scope
This Policy applies to AryAI and all of its operating entities, directors, employees, contractors and representatives, in every jurisdiction in which we operate.
It applies to all AryAI products and services, including AI factory design and delivery, programme and PMO services, advisory engagements, and the NYAYA suite of AI governance platforms (SABHA, PRAHARI, AGAMA, DARPAN, PRAMANA, RAKSHA, MUDRA and SETU), together with offerings for individuals.
It extends to our supply chain: vendors, colocation and facilities partners, hardware and network suppliers, and subcontractors are expected to meet the standards in Section 10 as a condition of doing business with AryAI.
3Policy statement
ESG is engineered into everything we do. It is a design input — never an option added at the end, and never a claim we cannot evidence.
AryAI commits to delivering AI infrastructure responsibly and efficiently, to building AI governance technology that protects the people AI decisions affect, and to conducting our own business with the same discipline, transparency and accountability that our platforms enforce for others.
Every engagement carries our ESG commitments as standard: energy-aware design, responsible AI and evidenced governance, built in from day one. Where a client requirement and this Policy conflict, we will raise the conflict openly and will not silently lower our standards.
4Environmental commitments
AI factories are energy-intensive by nature. We therefore engineer efficiency in from the first design review rather than reporting on it after the fact.
Energy-aware design. We specify high-density and liquid-cooled architectures where appropriate, and set measurable efficiency targets in every factory design, vendor selection and RFP response before anything is built.
Utilisation over waste. We set GPU and infrastructure utilisation targets that eliminate idle waste, treating stranded capacity as an environmental cost as well as a commercial one.
Responsible siting and power. We select and recommend colocation partners on evidenced criteria including renewable energy matching, low power usage effectiveness (PUE), water stewardship and grid impact.
Carbon and power telemetry. Power and carbon telemetry is included in every factory handover pack, giving clients an operational baseline for their own environmental reporting from day one.
Our own footprint. We minimise the environmental impact of our own operations, including travel discipline, responsible procurement, and the reuse or responsible disposal of equipment.
5Social commitments
AI that people can trust, built by teams people can trust.
Protecting people affected by AI. The NYAYA logic model challenges AI decisions for fairness, safety and harm before they execute. We will not knowingly build, deploy or govern AI systems that cause unlawful discrimination or foreseeable harm to the people they affect.
Skills transfer. We transfer skills to client teams on every programme, so capability remains with the client after we leave rather than creating dependency.
Fair labour and human rights. We hold ourselves and our supply chain to modern-slavery and fair-labour standards, and we prohibit forced labour, child labour, harassment and unsafe working conditions anywhere in our value chain.
Access and inclusion. We make enterprise-grade AI governance accessible to individuals as well as corporations, and we build our teams on merit, dignity and equal opportunity.
Health, safety and wellbeing. We maintain safe working environments on every site and programme we operate, including construction-adjacent and data-centre environments, and we require the same of our partners.
6Governance commitments
Governance is not a department at AryAI — it is our core product, and we apply the same discipline to ourselves.
Evidenced AI decisions. Every AI decision under NYAYA is sealed as replayable, auditable evidence. We design our platforms so that claims about AI behaviour can always be proven, not merely asserted.
Regulatory alignment. Our policy packs and platforms map to the EU AI Act, ISO/IEC 42001 and the NIST AI Risk Management Framework, and we track emerging AI regulation in every market in which we and our clients operate.
Ethical business conduct. We prohibit bribery, corruption, facilitation payments and fraud in all forms. We operate transparent reporting, ethical sourcing and anti-bribery controls on every engagement.
Data protection and security. We handle client, partner and personal data lawfully and securely, applying data-protection-by-design across our platforms and programmes.
Board-level accountability. ESG performance is owned at the most senior level of the business and reviewed as a standing item of executive governance, not delegated out of sight.
7Implementation lifecycle
This Policy is operationalised through a four-stage lifecycle applied to every programme and product:
| Stage | Commitment |
|---|---|
| 1 · Specify | ESG criteria are written into every design, vendor selection and RFP response — efficiency targets, responsible sourcing and fairness requirements set before anything is built. |
| 2 · Build | Energy, safety and supply-chain metrics are tracked as programme KPIs alongside cost and schedule — reviewed at every governance cadence, not just at handover. |
| 3 · Govern | The NYAYA suite enforces fairness, safety and policy compliance at AI runtime — pre-execution challenge, not post-incident apology. |
| 4 · Evidence | Measurable ESG outcomes — carbon, fairness, compliance — are delivered as sealed, regulator-ready reporting in every review pack and factory handover. |
8Roles & accountability
| Role | Responsibility |
|---|---|
| Chief Executive Officer | Owns this Policy, approves it, and is accountable for ESG performance across AryAI. |
| Executive leadership | Embeds ESG criteria in commercial decisions, vendor selection and product roadmaps; reviews ESG performance as a standing governance item. |
| Programme & delivery leads | Apply the Specify–Build–Govern–Evidence lifecycle on every engagement and report ESG KPIs at each governance cadence. |
| All personnel | Understand and comply with this Policy, and report suspected breaches promptly through the channels in Section 12. |
9Measurement & reporting
ESG metrics — including energy efficiency, carbon telemetry, safety performance, supply-chain compliance and AI fairness outcomes — are tracked as programme KPIs alongside cost and schedule.
Every client review pack and factory handover includes evidenced ESG outcomes in a form that boards, auditors and sustainability teams can rely on.
AryAI reviews its consolidated ESG performance at least annually and publishes a public ESG statement summarising commitments, progress and priorities.
10Supply chain & partners
We select vendors, colocation providers and subcontractors on evidenced ESG criteria as well as technical and commercial merit, including energy performance, labour standards and business ethics.
Partners are expected to comply with applicable environmental law, modern-slavery and fair-labour requirements, anti-bribery law, and the substance of this Policy. Material non-compliance is grounds for remediation requirements or termination.
ESG requirements are written into our RFPs, contracts and vendor onboarding — set before the work begins, not negotiated after it.
11Framework alignment
This Policy and the controls that implement it are informed by, and aligned to, the following frameworks and instruments: the EU AI Act; ISO/IEC 42001 (AI management systems); the NIST AI Risk Management Framework; ISO 14001 principles for environmental management; the GHG Protocol for carbon accounting; the UN Guiding Principles on Business and Human Rights; and the UN Sustainable Development Goals. Where frameworks differ, we apply the more demanding standard.
12Breaches & escalation
Anyone — employee, partner, client or member of the public — may raise a concern about a suspected breach of this Policy by contacting info@aryai.one. Concerns may be raised confidentially.
We prohibit retaliation against anyone who raises a concern in good faith. Substantiated breaches are remediated, reported to executive leadership, and — where required — disclosed to affected clients and regulators.
13Review & version control
This Policy is reviewed at least annually, and additionally on any material change to regulation, our operations or our product portfolio. All changes are versioned and approved by the Chief Executive Officer.
| Version | Date | Description | Approved by |
|---|---|---|---|
| 1.0 | 23 July 2026 | First issue. Finalised and approved for publication. | Chief Executive Officer |
14Approval
This Policy has been reviewed and approved for issue and takes effect from the effective date shown in the document control block above.