| Ardagh Group North America AI Applicant and Employment Notice [Effective 1/1/2026] |
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| Why You Are Receiving This Notice | The Illinois Human Rights Act, as amended, requires Ardagh Group S.A. (“Ardagh Group,” “Ardagh Glass Inc.,” “Ardagh Metal Packaging USA Corp.,” “we,” “us,” “our” or “the Company”) to notify employees and prospective employees whenever artificial intelligence (“AI”) is used to influence or facilitate covered employment decisions. Covered employment decisions include decisions with respect to recruitment, hiring, promotion, selection for training or apprenticeship, discharge, discipline, tenure, and/or other terms and conditions of employment as described in this Notice. This notice explains which AI tools the Company uses, what employment decisions they may influence, the purpose of each tool, the types of personal information processed, your rights under Illinois law, and how to request a reasonable accommodation. |
| AI Tools Used | AI refers to machine-based systems that use inputs to infer and generate outputs such as predictions, content, recommendations, or decisions that can influence physical or virtual environments. This definition includes “generative artificial intelligence,” a type of AI that uses sophisticated algorithms to “produce outputs that simulate human-produced content.” The following AI tools are used in our employment activities: Phenom (Version Phenom 2024): developed by Phenom. Thomas: developed by Thomas International. Gallup (Version Gallup Q12): developed by Selection Research. goFLUENT (Version 5.4x): developed by goFLUENT. Additional AI systems will be added to this list within 30 days of adoption, if applicable. |
| AI Use, Covered Employment Decisions, and Personal Information Processed | The Company uses certain AI systems to influence or facilitate the following covered employment decisions including: For applicants, Phenom is used to screen and/or rank applicants, recommend applicants for interview, assess job-related skills, support targeted job advertising, and flag applications for additional review. Phenom does this by bolstering impartiality and removing certain data points while matching candidates to jobs. AI driven insights are provided on website usage, job performance and talent pipelines. An AI chatbot supports candidate interactions and recruiter workflows. To the extent applicable, the Company also uses human review or oversight in connection with these decisions by validating and adjusting the assessment criteria. Phenom does not filter out candidates. For employees, Thomas International, Gallup and goFLUENT are used. Thomas International is used to provide online psychometric assessments to help retain and develop talent. Gallup is used to provide us with an employee engagement survey tool. It helps leaders to understand team needs, strengthen workplace culture and support our strategic people and culture goals. The tool analyzes survey responses, extract themes and flags personal information (PI) and toxic language. While outputs are validated by human reviewers, Gallup is not used in employment decisions. GoFLUENT is used to provide digital learning content, proficiency tests, conversation classes, and personalized learning paths via our learning platform. It utilizes generative feedback and suggests content. GoFLUENT is not used to determine promotion, performance, tenure, compensation or job duties. Oversight is provided by trained human evaluators and consistent benchmarks promote fair and comparable outcomes across users. Human oversight is embedded in assessment processes through the involvement of qualified assessors. Depending on the tool, these AI systems may process the following categories of personal information from applicants and/or employees: application information; resume/CV; employment history; education; skills assessments; interview responses; job-related communications; language skills; internal performance data; training records; and other job-related information. More information about your privacy rights is included in our privacy notice. |
| Positions or Job Categories Involved | Phenom people is used in connection with all open job positions offered by the Company. The other tools identified in this Notice are not used with respect to open job positions. |
| Reasonable Accommodation | Applicants and employees have the right to request reasonable accommodation related to the Company’s use of AI in covered employment decisions, if one is necessary. To request an accommodation:
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| Your Rights | Under 775 ILCS 5/2-102(L), it is a civil rights violation with respect to recruitment, hiring, promotion, renewal of employment, selection for training or apprenticeship, discharge, discipline, tenure, or the terms, privileges, or conditions of employment, for an employer to use artificial intelligence that has the effect of subjecting employees to discrimination on the basis of protected classes under this Article or to use zip codes as a proxy for protected classes under this Article, and for an employer to fail to provide notice to an employee that the employer is using artificial intelligence for the purposes described above. The Department of Human Rights shall adopt any rules necessary for the implementation and enforcement of this subdivision, including, but not limited to, rules on the circumstances and conditions that require notice, the time period for providing notice, and the means for providing notice. |
| Updates | We may update this Notice from time to time, including when adopting new AI tools or materially changing existing AI tools used for covered employment decisions. Where required, we will provide updated notices within applicable timeframes. |
| Contact Us | For questions regarding the Company’s use of artificial intelligence in employment decisions call 833-737-0006 or email us at privacy.NA@ardaghgroup.com. |