General-Purpose AI Code of Practice

At Proofpoint, we are committed to maintaining transparency, compliance, and ethical integrity in all aspects of our AI usage.  We recognize the growing importance of the General AI Code of Practice ("EU GPAI Code of  Practice") as a voluntary yet influential framework that supports implementation of the EU AI Act, particularly in relation to Articles 53 and 55.

Our Current Position

Our current operations do not fall within the scope of EU GPAI Code of Practice.  Specifically:

• Our use of AI falls under "minimal risk" under the Artificial Intelligence Act, https://www.proofpoint.com/us/the-artificial-intelligence-act
• We do not provide General-Purpose AI models, as defined in Article 3(63) of the EU AI Act.
• We do not integrate GPAI models into core AI systems.  Usage of GPAI models is limited to non-critical auxiliary functions.
• We do not engage in fine-tuning or architectural modification of GPAI models.

As such, the obligations outlined in the EU GPAI Code of Practice do not currently apply to our organization.

Our Commitment Going Forward

While the EU GPAI Code of Practice is non-binding, it sets important expectations for transparency, copyright compliance, and AI safety practices.  We remain attentive to those evolving norms and will reassess our compliance position if our operational use of AI changes in the future.

At Proofpoint, we are dedicated to proactively aligning with responsible AI governance frameworks to safeguard the trust of our customers, partners, and regulators.