AI Governance: From Policy to Responsibility (Part 2)

How ethics, bias mitigation, and accountability shape real-world AIPhoto by Scott Graham on UnsplashIn Part 1, we talked about the structural pieces of AI governance like policy, oversight, and operational control, and how those form the basic scaffold…


This content originally appeared on Level Up Coding - Medium and was authored by Jacob Gibbons

How ethics, bias mitigation, and accountability shape real-world AI

Photo by Scott Graham on Unsplash

In Part 1, we talked about the structural pieces of AI governance like policy, oversight, and operational control, and how those form the basic scaffolding for scaling intelligent systems. But having the structure in place doesn’t mean the outcomes take care of themselves.

The real test shows up when AI systems run headfirst into human values, social norms, and the internal politics of a company. This section looks at that pressure point and digs into how ethics, alignment, and accountability shape whether AI becomes a strategic advantage or something you end up explaining in a post-mortem.

What is “Ethical AI”? To me, this boils down to aligning with three things:

  • Societal Norms
  • Corporate Values
  • Human Rights

In exploring these alignments, there will absolutely be tradeoffs to make. Decisions that value privacy may hinder utility, and decisions that value transparency may hinder fair use or competitive advantages. To go about actually codifying ethical principles into policy, there are a few options, but committees and oversight boards generally win out here.

To give a brief example, my organization has an group called “AI Guidelines and Approvals” where use cases, plans of action, and solutionining thoughts must be addressed. There are considerations here for things like client work vs. internal work, the data being exposed, and more. A board of trusted individuals with both domain and business experience can help move the needle towards a balance between the three alignments above.

All this planning only goes so far. If there are inherent biases baked into models or data (whether they’re known or not), decisions can be made by the AI models that can affect the outcome of that model. In Part 1, I noted a famous case from Amazon where an AI tool built to scan resumes had a bias against women. Unfortunately there are a multitude of cases just like this one.

Photo by Christian Lue on Unsplash

Bias isn’t solved by tweaking a model alone. Engineers can measure and reduce it, but Governance decides what trade-offs are acceptable, who is affected, and when a system should be paused or redesigned. It sits in both domains, and without that pairing you end up with technical fixes that don’t change outcomes or policies that never get enforced.

If I were to build out a new process model to address biases in an organization looking to dive deep into AI, here’s how I’d approach it:

1. Review processes

  • A mandatory “model impact review” before deployment that checks for protected class effects, data provenance, and intended use.
  • Requires documentation of known limitations and escalation if a model affects hiring, lending, healthcare, or similarly sensitive domains.
  • Key point: it forces bias to be evaluated before a system is in production, not after complaints roll in.

2. Audit standards

  • A recurring audit cycle (for example, every 3 or 6 months) where models are re-tested against drift, demographic skews, and outcome disparities.
  • Uses a standard set of metrics defined by the organization so teams can’t cherry-pick.
  • Key point: bias isn’t a one-time check because data and behavior shift over time.

3. Accountability structures

  • A clear owner (not a committee) who is responsible for signing off on fairness results and pausing or retracting a model if thresholds are violated.
  • Includes a reporting path to a governance board if the risk level is high enough.
  • Key point: without a name attached to responsibility, accountability evaporates.

Accountability in AI isn’t evenly distributed, even if the work is. Executives decide whether the organization uses AI and where it’s allowed to touch clients, revenue, or regulated domains, which means they inherit the reputational and legal fallout when something goes wrong.

Product owns the translation layer between ambition and implementation, so they’re accountable for prioritizing safe use cases, defining acceptable risk, and making sure privacy and bias concerns are surfaced before build starts.

Engineers execute, but their responsibility sits at the technical level: model choice, data suitability, traceability, and documenting limitations. Their role relies on understanding domains well enough to know that what they’re doing is actually the right thing and that nothing accidentally makes it’s way into a model unintentionally.

Photo by James Allen on Unsplash

The tension shows up because decision-making is distributed, but blame isn’t. An engineer can misconfigure a model, but the headline will still point to leadership. That’s why clear escalation paths and approval rights matter, so that accountability isn’t determined after a failure, but before anything ships. Consider the following example where an AI model is slated to predict loan eligibility:

A financial institution rolls out an AI model to predict which applicants are likely to be approved for loans. After a few months, regulators notice the model systematically rejects certain demographic groups at a higher rate.
Engineer’s role: they built and deployed the model, selected features, and implemented the scoring thresholds. They didn’t detect bias in the training data or test outputs against protected classes.
Product’s role: they defined the use case and prioritized efficiency in loan approvals, prioritizing speed over thorough fairness review. They didn’t require additional oversight for a high-impact application.
Executive’s role: they approved AI use in customer-facing lending decisions and set the risk appetite for automated approvals, effectively green-lighting the deployment without stricter governance checks.
When the problem comes to light, the public and regulators hold the leadership accountable. Engineers and product teams may face internal scrutiny, but the executives bear the reputational, legal, and regulatory consequences. Were there a more comprehensive oversight process in place, many missteps may have been caught prior to the deployment of this model.

Ethics, bias, and accountability aren’t separate checkboxes. They work together to determine whether AI actually creates value or ends up causing problems. Ethical principles guide which biases are acceptable and which aren’t, bias checks show whether those choices hold up in practice, and accountability makes sure someone is responsible when things go wrong.

Getting it right also requires the right culture and incentives to reinforce those rules. Together, these things form a feedback loop where policy informs practice, practice surfaces issues, and issues surface a need for leadership to adjust policy as needed. As we wrap up this section, the next part will take a closer look at transparency, risk oversight, and how governance policies need to evolve as AI systems become more complex and impactful.


AI Governance: From Policy to Responsibility (Part 2) was originally published in Level Up Coding on Medium, where people are continuing the conversation by highlighting and responding to this story.


This content originally appeared on Level Up Coding - Medium and was authored by Jacob Gibbons


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