Responsible AI in marketing: how can the industry preserve trust?

Enrique Ramirez: [00:00:00] Hello, everyone, and welcome to Trading Talks, a podcast by the International Chamber of Commerce. My name is Enrique Ramirez, global marketing and media director at Grupo Bimbo. And I’ll be your host for today’s episode, where we will be exploring the responsible AI in marketing and advertising and how the industry can preserve trust. While technology rapidly reshapes market practices and global media, the yellow transformation and AI integration focus on how media, data and technology drive business growth in a responsible way. I’m really pleased to be joined today by Alexander Montgomery. Alex is currently principal corporate counsel at Microsoft, where he advises consumer marketing teams supporting Microsoft Copilot and Microsoft AI business. And Alex also was one of the primary drafters of the recently published ICC guidance paper on responsible AI in marketing. Without further ado, let’s get started.

Alexander Montgomery: [00:00:53] Thanks so much, Enrique. I’m looking forward to the conversation.

Enrique Ramirez: [00:00:56] Okay, Alex, I will start with a question regarding rates and red lines, because we all know that AI has moved very quickly from being a behind the scenes optimization tool to something that actually shapes creative content targeting and even consumer perception at scale. So AI is transforming not only the creative content itself, but how ads are targeted and personalized at scale. This brings up the dichotomy. One where AI is making advertising more relevant but also amplifying risks, particularly for vulnerable audiences. Alex, I’d love to hear about the risks that you’re seeing and how marketers can or should assess whether the use of AI is crossing the line from relevance to a responsible or even deceptive behavior.

Alexander Montgomery: [00:01:45] Yeah, it’s a great question. Um, I think it also, I would put it, I would slightly reframe the question in that I don’t know that it necessarily is amplifying the risks, but I think it creates the potential for risk. And what I mean by that is I think AI, especially when it comes to content creation, creation or asset creation for marketing, has made things you’re able to move so much more quickly, faster, more cheaply. You can really craft storytelling exactly how you want it to be versus the traditional approach of, let’s say, hiring talent or going through more manual means of creating content or serving content. And I think that to me is part of where some risk comes up and that people or marketers, agencies can move so quickly now that there is, I think, less time to think through what are we doing? How is this going to come off? What is the perception or impression that we’re creating with this advertisement? Um, and so I think it’s at this point, with everything moving so quickly, it’s actually a great time to take a step back, take a beat and try and really think about What are we putting out there? How is AI impacting consumer perception? And I think the risks are there’s legal risks. Certainly there’s new laws coming out about how you can use AI in advertisements. But I also think there’s PR risks as well. I think AI is a hot topic in the public sphere, and sometimes there’s some mistrust about it.

Alexander Montgomery: [00:03:20] And so, you know, when you’re creating advertisements, you’re thinking not just about business objectives and potential legal risks, but also how is this going to come off to our target audience? Are they going to appreciate or mistrust use of AI? And to what extent do we need to tell them? Um, and I think to the second part of the question about how can marketers assess whether you’re crossing the line? I think the gold standard for me has always been, put yourself in the shoes of the consumer and understand that perhaps your target audience might have a very different or lesser understanding of AI and what is or is not AI, um, than the people who are creating the ads. Because when you’re in the industry and you’re seeing it and using it every day, you might have a different, um, tolerance or a different lens that you’re viewing it through versus the audiences that are actually seeing the advertisements. And especially, you know, folks that are older, very, are much younger, that aren’t familiar with perhaps familiar with AI as I am, you know, they have to keep in mind the lens that they’re looking at things through. But yeah, and I’m speaking sort of from the legal perspective as a lawyer, but Enrique, I’d be curious to see, hear what your thoughts are on the marketing side.

Enrique Ramirez: [00:04:38] Sure. I think the the risk is not the AI itself. It’s how far you push it without proper judgment. You know, for instance, in our case in Grupo Bimbo, uh, what we have learned is that the scale amplify mistakes. So governance has to scale faster than the technology.

Alexander Montgomery: [00:04:57] I think that’s a that’s a great way to put it. And I would agree that like many types of technology, it’s not a problem in and of itself. It’s really how it’s used and how it’s deployed that really makes the difference. Yeah.

Enrique Ramirez: [00:05:13] Okay. Now regarding trust, not because it’s a great topic at a time when regulation is clearly still trying to catch up. How do you ensure customer trust keep pace with innovation and where are the biggest pressure points?

Alexander Montgomery: [00:05:29] Yeah, I think trust when it comes to AI is probably one of the biggest or should be one of the biggest focus points, because there’s a lot of competition amongst companies, each trying to outdo the others to what capabilities we have or what AI can do. But to me, the the differentiator, I think, in the long term will really be what tool or what advertising can people trust? What do they when they see it? Do they believe what is being said to them about the product that’s being advertised or what they’re seeing on the screen? Um, and so I think some of the biggest pressure points, um, often are, for example, product accuracy, ensuring that how products are marketed and advertisements is accurate and that there aren’t assumptions made that then create a gap between consumer perception and what is being intended to be said through the advertisement. Um, and so I think the more that companies can build trust, I think there’s a variety of ways to do that, whether that’s, um, you know, focusing on responsible AI practices or, um, you know, disclosing use of AI when it makes sense. Um, I think the more that companies can focus on building trust, um, rather than just, you know, getting content out there as quickly as possible. Um, I think that makes a huge difference. And as a sort of a tide that floats all boats, in my opinion.

Enrique Ramirez: [00:07:00] Yeah. Totally agree. And I mean, from my perspective and also from the marketing side, you know, what I’ve seen in practices that Ross is not built in campaigns. It’s built in system and, and persistent. I mean, how everything is really connected, like the AI agents, platforms and workflows, helping to enhance your strategy and the rest of the marketing areas. I mean, not only media or marketing in general, because if the system is transparent, consistent, and accountable, the Apple tends to follow, you know.

Alexander Montgomery: [00:07:33] Exactly. I think that’s a great way to put it. And I think it’s also important to note that trust, as you said, it’s not built in a campaign. And I also think it’s not built just with your use of AI. It’s something that goes across the brand and across the company. Um, I think I work at Microsoft in one of our taglines is Microsoft Runs on Trust. And I think that’s not just with our AI, but across the board. And so I think companies and marketers should think about that broadly, and not just in a given ad or a given campaign, but really building that up across the board.

Enrique Ramirez: [00:08:03] As policymakers increasingly turn their attention to AI governance. Where do you see the role of self-regulation like the ICC Advertising and Marketing Communications code adding the most value? Well, first of all, and building on that, I don’t know if the audience knows, but I have some good news because ICC has just released new guidance on responsible AI in marketing to help companies apply these principles in practice. So, Alex, how important are tools like this in helping the industry keep pace with such rapid technological change?

Alexander Montgomery: [00:08:37] I think it’s a great question, and I think self-regulation is perhaps more important now than ever. We’re in a time of incredibly rapid change with technology, with the regulatory landscape, and having a set of principles that we can all ascribe to and believe in, I think is truly important. Um, I think that there is, especially when it comes to AI, there’s a lot of what I view as sort of monkey see monkey do. Everyone wants to keep pace with the other. If there’s a company that’s marketing in a certain way, another company wants to do that exact same thing. And there’s often a question that I get internally when we’re looking at a marketing campaign. Oh, well, can we do this because this other company is doing it this way or this other company is doing it that way. I think when companies come together around a shared set of principles, it levels the playing field and ensures that we’re all working with the same set of tools for the right reasons. Um, and speaking of tools, the guidance on responsible AI and marketing, I think is a very useful resource because it helps. It lays out the questions that marketers should be asking themselves when they’re using AI in marketing to ensure that it’s being done responsibly, and that their internal checks, but also ensuring that the perception, consumer perception externally is really taken into account, and how ads are created and delivered is done in a way that is ethical and something that a company can be proud of, and that builds trust across the industry and those guidelines.

Alexander Montgomery: [00:10:20] I think it’s important to to note, yes, I was one of the drafters, but that was actually the result of a large effort across industries and stakeholders that are all members of the ICC. So when we were drafting that, there are a lot of voices that contributed to that piece of guidance. And so it’s really a statement from across the industry, both from, you know, regulatory organizations, companies, marketers, lawyers, you name it. We all came together to put that piece of guidance in place to really help provide a useful resource, um, in such an important time. Um, and I guess on that note, Enrique, how do you see self-regulation playing out in your experience at Grupo Bimbo?

Enrique Ramirez: [00:11:10] Yeah. Well, to be honest, um, but we are defining now these new policies, obviously taking advantage of the ICC guidance. The idea is always to put, um, the client, the consumers in general in the center and not only Grupo Bimbo, I think is something that all the industries in general have to do and apply because, uh, even with the rules, the definition of what’s acceptable keeps evolving.

Alexander Montgomery: [00:11:39] That’s totally right.

Enrique Ramirez: [00:11:42] Uh, nowadays, much of the current debate, particularly at the international level, focuses on the risks of AI fueling misinformation and advertising. However, these issues are often more subtle and already addressed through established principles around the misleading practices. Do you see AI as fundamentally changing those boundaries, and do you think AI is changing the nature of what we should consider misleading, and how should existing standards able to keep up?

Alexander Montgomery: [00:12:13] Yeah, this is an interesting question because, um, in writing the, the guidance on responsible AI and marketing the ICC, this is something that we grappled with quite a bit because I think to me, AI in and of itself isn’t fundamentally changing the boundaries or isn’t by itself creating a misleading perception. It’s really, again, how it’s used. And there are established laws across the world for consumer protection purposes that if an if an ad is misleading, it doesn’t matter whether it was AI that caused it to be misleading or false claim or something. If it’s misleading, it’s misleading and shouldn’t be out there. Um, and I often take the example of, you know, Photoshop, if an image that we’re putting out, uh, in an ad is misleading, whether it’s created by Photoshop or AI shouldn’t matter. It shouldn’t be out there if we’re creating an impression that isn’t true. Um, but I do think that it, it creates, going back to my prior point, I think it creates a realm of possibilities where the opportunity or the potential risk of even inadvertently creating a false or misleading impression can occur. Um, and there’s, you know, there’s a lot of different perspectives on this. Like, for example, um, even recently in New York, there’s a law that was passed called the synthetic performer bill, where essentially, if you’re in New York, you run an ad that has an image of a human and that human was actually created by AI, you have to disclose that. Um, and I think the purpose is, is a, a reasonable one that people should know whether what they’re looking at is real or not. Yeah. Whether it’s misleading and of itself is another question. But there’s, it creates situations where I think rightly or wrongly, regulators want to make sure that that consumers are protected and that there’s sort of an ethical use of AI so people understand what they’re looking at and have the full picture.

Enrique Ramirez: [00:14:21] Yeah. Actually, what I see is that AI doesn’t change the intent, but it changes the execution in ways that are harder to detect. You know, so yeah.

Alexander Montgomery: [00:14:31] Exactly. That’s why there’s been a lot of focus on watermarking, provenance of images and things like that. So people, um, again, have a, have a clear understanding of what they’re looking at. And I think that this is an area that’s going to continue to evolve and this sort of nexus between AI itself and whether it’s misleading or not, it’s going to continue to get flushed out. Um, you know, for the foreseeable future. So we’ll have to see what happens.

Enrique Ramirez: [00:14:58] And I want to know about your own experience at Microsoft. What does responsible AI implementation actually look like in practice? I mean, where did you start and would it be in some of the key lessons along the way? I think this is something really important for our audience.

Alexander Montgomery: [00:15:15] Yes. Um, I think at Microsoft as one of the first movers and leaders in, in AI, um, you know, over the past couple of years, from the very beginning, it started from a place of we recognized the power and importance of this technology and that it had to be used responsibly and that we had a significant obligation to ensure that we have responsible AI standards that we follow and encourage those who use our technology to follow. And to me, that’s an incredible. It goes to our discussion about trust. Um, having a responsible AI practice, AI standards that you follow and implement, um, both internally and externally, ensures that that trust is honored and kept and enhanced. Um, and so just as an example, you know, for us internally at Microsoft, we have, you know, standard types of review that we would do for any advertisement before we put it out. But when it comes to AI, we have a whole separate team that is dedicated solely to ensuring responsible use of AI. And we do a much deeper dive on that than we would have before AI was around. And so I think it’s that commitment to both quality and trust and responsible use of AI. It starts internally. It starts from the top. And I think it’s an incredibly important part of the process.

Enrique Ramirez: [00:16:46] Well, I’m not to take you to, to share that. Because in my experience, for instance, you don’t scale AI first, you scale it, control first, then AI on top of that. I don’t know, right. Okay. Uh, looking ahead, 2 or 3 years, what is the one area where you think the industry still needs much clearer guidance or alignment when it comes to AI in marketing?

Alexander Montgomery: [00:17:12] I think probably the biggest one is what we’ve talked about. I think the issue of AI labeling and when use AI needs to be disclosed or not, um, is something that will continue to be there’s more and more regulation coming out in that area. And I, what I’m hoping is that there will be a good balance struck between the interests of consumer protection, but also the realities of the advertising world. And both, I think, need to be taken into account. And so I think there will be more and more discussion on that. New regulations will come out. And I also think that that’s another place where self-regulation and committing to a shared set of principles can be really important, regardless of what the law says or how an individual company might act. When we all come together and believe in a certain set of principles, we can handle these types of issues, um, in a really positive and impactful way.

Enrique Ramirez: [00:18:19] Yeah. From my perspective, um, the biggest gap is the first party that and how that’s going to operate. Right now everyone is building closed ecosystem. I mean, all the enterprises in general, but AI needs connected data to work properly. And the issue is we still don’t have clear rules on how to connect the data safely and responsibly. And if we don’t solve that, AI will stay limited or scaled for risk instead of value.

Alexander Montgomery: [00:18:48] Yeah, exactly. And I think a lot of this also comes down to, even though it feels like AI has been around for a long time at this point, this current age of AI that we’re in is still pretty new, and we’re still trying to figure out what can this technology do? How can how can it be used? How should it be used or not used? And so and things are changing so rapidly that I think it’s an area where, again, sticking to sticking to core principles is important at a time when things are changing so rapidly. And so we’ll see. It’s it’s a very exciting time. It’s an exciting time to be a lawyer. It’s an exciting time to be a marketer like you, I’m sure. So we’ll see how things go.

Enrique Ramirez: [00:19:31] Sure. And I have something that in my head for a while. Do you think the industry is currently underestimating any specific risk around AI in advertising or the contrary? Are the areas where the debate has become overstated.

Alexander Montgomery: [00:19:48] I think my answer to that is probably a bit of both. Um, I think I think there are areas where the risk of AI probably is underestimated. And I think there are areas where, like I sort of mentioned before, there can be overcorrection, um, due to I think public perception, but also fears around sort of the unknown of where this technology is going and how it can be, how it can be used. So I, my, my opinion is it’s hard to say, um, just because laws and industry practices vary so much, but I think that will be continue to be sort of the yin and yang of underestimating, perhaps overcorrecting and overestimating and vice versa. And I think like any area over time, eventually those things will start to align in a place that people are comfortable with.

Enrique Ramirez: [00:20:43] Yeah, exactly. I totally agree. And I think, yeah, it’s a bit of both because, um, I think we are underestimating the impact on the talent. I mean, we’re focused on scaling AI that we’re losing our best strategies if they feel replaced instead of elevated. But at the same time, some of the debate is overstated. I mean, because many of the challenges we are still seeing advertising come from, uh, how decisions are defined and executed, not just from the algorithm itself. So I think the priority should be, um, more simple, uh, use AI to elevate the quality of the decisions in general, not just to scale what we already have.

Alexander Montgomery: [00:21:29] Right. And I think the, the point you made about talent is, is also a good one and is something that sort of is AI going to replace this or isn’t going to be sort of an assistive technology? That debate is going to continue on no matter what. But on the talent side, it’s interesting that New York law that I mentioned, that was sort of a great example of the the different interests at play. And on the one side, you have advertising companies and federations saying, why do we need to disclose something that isn’t misleading? On the other hand, you have, you know, talent organizations like Sag-Aftra saying this is important. You know, talent isn’t. We’re basically taking opportunities away from talent. There should be some protection for that. And the public needs to know. And so I think that that dichotomy and that continued debate is going to be an interesting one to watch.

Enrique Ramirez: [00:22:26] Yeah, totally agree. But okay, enough with the doom and gloom. Let’s also share the possibilities. Yeah. I mean, not everything is in that in that respect. But yeah. Let’s share. Yeah. Go ahead.

Alexander Montgomery: [00:22:40] Please go ahead.

Enrique Ramirez: [00:22:41] I’d be very keen to share one of the smartest or innovative, responsible uses of AI in marketing that. Personally, I recently come across. For instance, at Grupo Bimbo, we are integrating AI into how we make marketing and media decisions. You know, but with a very clear focus on responsible use at scale. It’s not just about optimization. It’s about building the rules around how we use data, how we stay transparent, and how we show up to consumer. And because AI can scale performance fast, very fast, but it can also scale a risk at just as fast. So for us at Grupo Bimbo, responsible AI is part of the operating system. And we get that right. Ai becomes a trusted way of growing the business.

Alexander Montgomery: [00:23:33] And that’s very well said. I think the same, I would say the exact same is happening over here at Microsoft. And I do think that AI presents a lot of really great positive possibilities if done responsibly? If the right things are considered. Um, I love a great advertisement, and I think that AI gives you the opportunity to do storytelling the right way, the way you want to do it. You’re not sort of restricted as much as you were before. You can get content out. You can do it quickly and effectively. And as long as you’re doing it responsibly and you have the right things in mind, it can really be a great, a great tool that serves as a catalyst for, for industry change. And I think it’s an exciting time.

Enrique Ramirez: [00:24:15] All right. Thank you very much, Alex, for our discussion today and for sharing. Your experience was really insightful. And thank you, obviously, to our listeners for tuning in. See you next time.

Alexander Montgomery: [00:24:26] Thanks, Enrique. It was a pleasure.

[00:24:29] That was Trading Thoughts, a podcast by the International Chamber of Commerce. Don’t forget to follow us and give us a like. Thanks for listening.