Approach to Artificial Intelligence

  • Artificial Intelligence (AI) is developing rapidly. Appropriate use of AI will help us to achieve our purpose of building a brighter future for all. We recognise that a failure to govern and manage AI systems effectively may lead to undesirable consequences such as incorrect decision-making, compliance failures and poor customer outcomes. We aim to address these risks through our governance and compliance program.

    We have a principles-based approach to the policies governing the design, development, deployment and use of AI systems by the Bank.

    The six AI principles are:

    • Human, social and environmental well-being
    • Fairness
    • Transparency
    • Privacy and Security
    • Reliability and Safety
    • Accountability

    Our AI Systems are also subject to the Bank’s other policies, as relevant. 

    The Bank’s use of electricity and water for computing in our Australian data centres is subject to our operational emissions targets. 

    Further information on our progress on targets and our approach to managing our operational and supply chain climate impacts is outlined in our climate reporting.

    For further information, see our position on use of AI and renewable energy and water.

Our definition of AI

  • We view AI as a machine-based system that independently learns from data, designed to operate with varying levels of autonomy and that can, for explicit or implicit objectives, generate outputs such as content, predictions, recommendations, or decisions influencing the environments they interact with. AI includes technologies such as machine learning, Generative AI (identifies patterns and relationships in data, including supervised, unsupervised and reinforcement learning), dynamic or adaptive models, speech recognition, natural language processing and computer image recognition.

Using AI to improve customer outcomes and experiences

Partnerships that drive innovation

Responsible use of AI

The following six AI Principles were developed to guide the design, development, deployment and use of AI systems by the Bank: 

Human, social and environmental well-being

AI systems should advance human, social and environmental wellbeing as well as facilitate respect for human rights, diversity, and the autonomy of individuals. To justify the balance of potential harms and benefits that an AI system delivers means that other solutions, including not deploying any system, have been considered and ruled-out because they do not realise the same overall benefits delivered by the AI system. 

Fairness 

All people should be treated fairly and must not be unfairly discriminated against. Where AI systems contribute to decisions and outcomes, those decisions and outcomes are judged against the same standards that would apply to decisions and outcomes made entirely by humans. 

Transparency 

AI systems should be transparent so that their manner of operating and outputs can be readily understood, reproducible and, where appropriate, contested. Reference resources must be written in plain language and at an appropriate level of detail. 

Privacy and Security 

AI systems must ensure security of data and comply with privacy and data protection laws, including in accordance with the Bank’s privacy and security policies. 

Reliability and Safety 

AI systems should operate reliably, perform consistently and in accordance with their intended purpose. AI systems should not pose unreasonable safety risks, and should adopt safety measures that are proportionate to the potential risks. 

Accountability 

Human oversight of AI systems is necessary. There must be sufficient oversight by individuals with relevant expertise in the technology, the intended use, benefits and risks relevant to the AI system. 

Events

Date: December 10th -15th, 2024

Location: Vancouver, Canada

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Papers

 

Date: December 9-15, 2025

Location: San Diego, CA

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Date :  April 24-28, 2025

Location : Singapore

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Date :  June 11-15, 2025

Location : Nashville TN

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Date :  June 10-13, 2025

Location : Sydney , Australia

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Date : June 16-19, 2025

Location: New York, USA

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Best Paper Award to CommBank

Date :  Dec 2-4, 2024,

Location : Canberra, Australia

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Research

AI Labs publications

Authors: Arshnoor Kaur, Amanda Aird, Harris Borman, Andrea Nicastro, Anna Leontjeva, Luiz Pizzato, Dan Jermyn
Venue: 33rd ACM International Conference on User Modeling, Adaptation, and Personalization (ACM UMAP 2025 NYC)

Publication Date: June 2025

Link: https://dl.acm.org/doi/pdf/10.1145/3699682.3728339

Summary: In this paper, we tested whether LLM synthetic personas can answer financial wellbeing questions similarly to the responses of a financial wellbeing survey of more than 3,500 Australians. We identified salient biases of 765 synthetic personas using four state-of-the-art LLMs built over 35 categories of personal attributes, noticed clear biases related to age, and as more details were included in the personas, their responses increasingly diverged from the survey toward lower financial wellbeing. With these findings, it is possible to understand the areas in which creating synthetic LLM-based customer personas can yield useful feedback for faster product iteration in the financial services industry and potentially other industries. 

Authors: Harris Borman, Anna Leontjeva, Luiz Pizzato, Max Jiang, Dan Jermyn

Venue: The Thirty-Eighth Annual Conference on Neural Information Processing Systems (Neurips 2024)

Publication Date: December 2024

Link: https://neurips.cc/media/PosterPDFs/NeurIPS%202024/100931.png,  https://arxiv.org/pdf/2411.05801

Summary:  
In this paper, we explored whether Large Language Models (LLMs) with specific Big Five personality traits behave like humans in investment scenarios. Using a simulated investment task, we found that LLM personas exhibited meaningful and consistent behavioural differences aligned with human expectations in areas such as learning style, impulsivity, and risk appetite. However, environmental attitudes were not accurately replicated. The study also found that LLMs behaved more like humans in simulations than in survey-based environments.​‌

Authors: Dan Jermyn, Luiz Pizzato, Anna Leontjeva, Naomi Ranjbar Kermany, Patrick Songco, Jack Elliott

Venue: IP Australia Patent

Filling date: March 2024

Link: https://ipsearch.ipaustralia.gov.au/patents/2024202048

Authors: Anna Leontjeva, Genevieve Richards, Kaavya Sriskandaraja, Jess Perchman, Luiz Pizzato

Venue: arXiv

Publication Date: March 2023

Link: https://arxiv.org/pdf/2303.08016  

Summary: The introduction of longer payment descriptions in Australia's New Payments Platform (NPP) has led to its misuse for communication, including tech-assisted domestic and family abuse. To address this, the Commonwealth Bank of Australia’s AI Labs developed a deep learning-based natural language processing system that detects abusive messages in transaction records. The paper outlines the nature of this abuse, the design and performance of the detection model, and the broader operational framework used to identify and manage high-risk cases.

Authors: Naomi Ranjbar Kermany and Luiz Pizzato in collaboration with Macquarie University

Venue: International Conference on Service-Oriented Computing 2022

Publication Date: November 2022

Link: https://link.springer.com/chapter/10.1007/978-3-031-20984-0_23

Summary: Session-based Recommender Systems (SRSs) typically prioritize recommendation accuracy, often favouring popular items and reducing diversity. However, diversity is important for user engagement and surprise. This study introduces PD-SRS, a Personalized Diversification strategy using graph neural networks to balance accuracy and personalized diversity in recommendations. Comprehensive experiments are carried out on two real-world datasets to demonstrate the effectiveness of PD-SRS in making a trade-off between accuracy and personalized diversity over the baselines.

Authors: Naomi Ranjbar Kermany, Luiz Pizzato, Thireindar Min, Callum Scott, Anna Leontjeva

Venue: RecSys '22: Proceedings of the 16th ACM Conference on Recommender Systems

Publication Date: Sep 2022

Link: https://dl.acm.org/doi/abs/10.1145/3523227.3547388

Summary: Australia’s largest bank, Commonwealth Bank (CBA) has a large data and analytics function that focuses on building a brighter future for all using data and decision science. In this work, we focus on creating better services for CBA customers by developing a next generation recommender system that brings the most relevant merchant reward offers that can help customers save money. Our recommender provides CBA cardholders with cashback offers from merchants, who have different objectives when they create offers. This work describes a multi-stakeholder, multi-objective problem in the context of CommBank Rewards (CBR) and describes how we developed a system that balances the objectives of the bank, its customers, and the many objectives from merchants into a single recommender system.

Authors: Naomi Ranjbar Kermany and Luiz Pizzato in collaboration with Macquarie University

Venue: WSDM '22: Proceedings of the Fifteenth ACM International Conference on Web Search and Data Mining

Publication Date: February 2022

Link: https://dl.acm.org/doi/abs/10.1145/3488560.3502191

Summary: In this paper, we demonstrate Fair-SRS, a Fair Session-based Recommendation System that predicts a user's next click by analysing both historical and current sessions. Fair-SRS optimizes recommendations by balancing accuracy and personalized diversity, using Gated Graph Neural Network (GGNN) for session graph embeddings and DeepWalk for node embeddings. This approach captures users' long- and short-term interests, providing fair and diverse recommendations from niche providers. Extensive experiments on real-world datasets show that Fair-SRS outperforms state-of-the-art baselines in delivering accurate and diverse recommendations.

Authors: Naomi Ranjbar Kermany and Luiz Pizzato in collaboration with Macquarie University

Venue: World Wide Web

Publication Date: September 2021

Link: https://link.springer.com/article/10.1007/s11280-021-00946-8

Summary: In this paper, we propose a fairness-aware multi-stakeholder recommender system using a multi-objective evolutionary algorithm (MOEA) to balance provider coverage, long-tail inclusion, personalized diversity, and recommendation accuracy. Our approach introduces a personalized diversification method to align user interests with long-tail recommendations and a P-fairness algorithm to ensure fair provider exposure. Experiments on real-world datasets demonstrate that our method effectively enhances item diversity and provider coverage with minimal accuracy loss.

Author: Luiz Pizzato

Venue: Information Fusion

Publication Date: November 2020

Links:  https://www.sciencedirect.com/science/article/abs/pii/S1566253520304267 

Summary: In this paper, we introduce and formally characterize Reciprocal Recommender Systems (RRS), which focus on "matching people with the right people" by recommending users to each other. Unlike traditional recommenders, RRS requires mutual acceptance for successful recommendations. We provide a comprehensive literature analysis of RRS research, highlighting algorithms, fusion processes, and key characteristics. We also discuss challenges and opportunities for future research, emphasizing the need for novel fusion strategies, exploration of emerging application domains in social matching, and the potential for extending RRS principles to collective people-to-people recommendations.

Authors: Naomi Ranjbar Kermany and Luiz Pizzato in collaboration with Macquarie University

Venue: IEEE international conference on services computing (SCC)

Publication Date: December 2020

Link: https://ieeexplore.ieee.org/abstract/document/9284606

Summary: In this paper, we introduce an ethical multi-stakeholder recommender system that balances three key objectives: recommendation accuracy, diversity of long-tail items, and provider fairness (P-fairness). By employing a multi-objective evolutionary algorithm (NSGA-II), our system aims to enhance user satisfaction and provider exposure by incorporating lesser-known items into recommendations. Through experiments on real-world datasets, we demonstrate that our method significantly improves item diversity and provider coverage with only a minor loss in accuracy.

Blog

CommBank had the opportunity to participate at NeurIPS 2024 as a Bronze Sponsor, supporting one of the most prestigious academic artificial intelligence (AI) conferences globally. It was held in the city of Vancouver bringing together the brightest minds in AI and machine learning (ML) fostering collaboration and innovation on an unparalleled scale.

A Colossal Gathering of Knowledge

NeurIPS 2024 was nothing short of monumental, with nearly 17,000 in-person attendees (20,000 in total) engaging in an extraordinary array of activities. The conference boasted an impressive lineup of 7 keynotes, 14 tutorials, 58 workshops, and much more. The latest research was presented in nearly 4,500 papers both in oral sessions as well as in posters. Suffice to say, it’s an overwhelmingly large conference where you can only attend a small portion of it, and you are left with a lot of homework after the conference. All these dedicated to unravelling the latest advancements and challenges in AI and deep learning research.

Among all of them, these were the highlights:

Listening to a few sessions with luminaries like:

  • Yoshua Bengio was an unforgettable experience. Bengio’s thought-provoking discussions on AI ethics left a lasting impression on participants and reaffirmed the significance of conferences like NeurIPS in shaping the trajectory of AI. Link to talks.
  • Sepp Hochreiter emphasised that we are reaching the industrialisation of AI and that although we are exploiting techniques like transformers for most of that work, we are going to create more specialised and diversified techniques as we industrialised AI. Link to talk.
  • Alison Gopnik had an interesting talk on looking at children and the way they learn to build AI systems. Link to talk.
  • Fei-Fei Li enlighten the audience on the history of visual intelligence and how visual intelligence is the key to unlocking further advances in robotics and augmented reality. Link to talk.
  • Ilya Sutskever received a test of time award and highlighted how although compute is growing, data is not growing on the same scale, hence different ways of training the next foundational models are needed. Link to talk.

Diving into Specialised Workshops

Given the speed of change in AI and the slow peer review process of such large conferences, the ideas of some of the papers are normally disseminated months ahead of the conference in pre-prints. Hence despite how amazing these top-conferences are, I always feel the biggest value from an attendant perspective comes from workshops, where late breaking ideas and more niche discussing can be had.

One of the standout workshops for me was the Table Representation Learning Workshop (TRL), which delved into novel ways of using deep learning with tabular data within machine learning frameworks. Despite the advancements in transformers and deep learning, XGBoost still reigns supreme in the enterprise because most data in businesses are structured, tabular data. The workshop had some amazing speakers, namely: Matei Zaharia argued that natural language query interfaces for analytics is a better fit for Gen AI than software engineering; Gaël Varoquaux talking about CARTE a table foundation model; and Andreas Mueller talking about MotherNet, a very interesting approach to foundational model for tabular data;

Other workshops worth checking out include: 

And last by not least the Workshop on Open-World Agents: Synnergizing Reasoning and Decision-Making in Open-World Environments (OWA-2024) where we presented our paper:  Do LLM Personas Dream of Bull Markets? Comparing Human and AI Investment Strategies Through the Lens of the Five-Factor Model

Infographic displaying visual representation of LLM powered personas

At CommBank, our commitment to advancing artificial intelligence (AI) is a key part our Technology strategy. As a leading financial institution, we recognise the transformative potential of AI in enhancing our services, improving customer experiences, and driving operational efficiency.

Our participation in the International Conference on Learning Representations (ICLR) 2025 in Singapore as a Gold sponsor underscores this commitment. ICLR is well known for presenting and discussing novel research in AI and machine learning, making it an ideal platform for us to engage with the global AI community, share our insights, and learn about the latest advancements in the field. 

Figure 1: CBA Booth was a popular spot


ICLR 2025 featured a range of research with over 11,000 submissions, approximately 32% acceptance rate, and 3,827 papers accepted. Submissions increased by over 60% from the previous year, reflecting the rapid growth of the AI field.

In terms of the main trends, the conference highlighted topics from agentic AI systems and multi-step reasoning to new fine-tuning strategies, advances in foundational models, and a strong emphasis on AI safety, alignment and real-world deployment.

We're excited to share trends and key takeaways from the conference, including insights from a selection of papers, workshops, and talks.

Agentic Systems and Open-ended Learning

Research of agentic AI systems was more prominent compared to NeurIPS 2024. Key talks emphasised open-ended learning approaches for such agents. For example, in his keynote, Tim Rocktäschel (Google DeepMind and University College London) advocated for training agents via “foundation world models” that generate diverse simulated environments, enabling agents to acquire more general and robust behaviours (see Figure 1). This open-ended paradigm aims to produce AI agents that can endlessly generate and tackle novel tasks, moving beyond narrowly optimised solutions. Early results are promising, we’re seeing self-referential self-improvement loops where AI agents can refine themselves through automated prompt engineering, automated red-teaming, and even AI-vs-AI debates.  

The drive toward agentic models matters because next-generation AI will likely need to operate autonomously in complex, changing environments. We should start thinking about how to design and evaluate systems in CommBank that learn from interaction and remain adaptive when facing unforeseen tasks.

Another recommended paper in the field of Agentic would be AFlow: Automating Agentic Workflow Generation by Jiayi Zhang et al. is a framework designed to automate the creation of agentic workflows using Monte Carlo Tree Search (MCTS). It refines workflows through code modifications and execution feedback. Initial experiments show promising results but highlight the need for further research, particularly for complex tasks in banking.

Figure 2: A demonstration of Genie 2 model that can generate a game from an input image


Fine-Tuning and Adaptation Techniques

With foundation models now widespread, a practical challenge is how to adapt these large models efficiently to specific tasks or evolving data. ICLR 2025 highlighted many advances in fine-tuning methods that make adaptation more accessible. A recurring theme was parameter-efficient fine-tuning: instead of retraining massive models from scratch, researchers are devising lightweight adapters (e.g. LoRA modules) that tweak only small portions of the model.

While this method is not new, ICLR 2025 was rich of various improvements over existing LoRA methods. One standout paper introduced LoRA-X, a technique allowing fine-tuning parameters to be transferred between different base models without any retraining. This approach addresses a common problem – when a foundation model is upgraded or replaced, we can carry over the learned task-specific adaptors without needing the original training data or costly re-training. Such innovations mean practitioners can keep models up-to-date and domain-specialised with minimal compute overhead.

More broadly, the conference underscored that adaptability is crucial for real-world AI: future systems should be easy to fine-tune on new tasks or data.

Some additional papers in the fine-tuning space worth highlighting include:

AlphaEdit: Null-Space Constrained Knowledge Editing for Language Models by Junfeng Fang et al. introduces AlphaEdit, a novel method for updating specific knowledge in Large Language Models (LLMs) without disrupting existing information. By projecting parameter updates onto the null space of preserved knowledge, AlphaEdit ensures that new edits are localised. This approach improves the preservation of original knowledge by 36% in GPT and LLama models.

Preserving Diversity in Supervised Fine-Tuning of Large Language Models by Ziniu et al. presents Entropic Distribution Matching (EDM), a technique to mitigate overfitting and loss of output diversity during supervised fine-tuning. EDM aligns the output distribution of the fine-tuned model with that of the pre-trained model, thereby maintaining the model's ability to generate diverse responses. This method enhances generalisation and robustness across various tasks.

Evolving Foundation Models

This year ICLR demonstrated that foundation models remain central topic in AI research, but the focus is shifting from simply scaling up model size to understanding and extending these models’ capabilities. Many works addressed issues like bounding model capabilities, reducing hallucinations, and using synthetic data to overcome training data gaps.

This reflects a maturation of the field: rather than chasing ever-bigger architectures, researchers are consolidating knowledge about how to optimise and reliably deploy the powerful models we already have.

At the same time, foundation models are expanding in scope. New multimodal models unveiled at ICLR can handle new modalities. For example, one presentation showed a hierarchical vision-language-action model (HAMSTER from NVIDIA), that transfers knowledge from simulations to real-world robotics tasks.

Researchers also showcased architecture innovations (such as hybrid Transformer–state-space models) to make large models more efficient in handling long contexts and high throughput.

Notably, a keynote by Danqi Chen highlighted that academia is finding ways to contribute to foundation model development by innovating under resource constraints – for instance, building smaller but capable models, improving training data quality, and layering new fine-tuning methods on open-source models. All these efforts indicate that foundation models are evolving not just in size, but in versatility and accessibility.

We can expect the next generation of foundation models that are more efficient, cover multiple modalities, and be easier to adapt in smaller settings.

Focus on AI Safety and Robustness

Finally, AI safety was a significant theme at ICLR 2025, indicating an increasing awareness that more advanced models need to be reliable and aligned with human intentions. Several invited talks addressed how to build safe and secure AI systems. Zico Kolter’s talk, for example, was focused on building robust AI systems that enforce strict safety constraints on models. He discussed recent techniques to harden models against adversarial exploits and “jailbreak” attacks, such as robustness at the training stage and even data pre-filtering stage to prevent users from manipulating an LLM’s outputs in harmful ways.

As AI systems become more agentic and ubiquitous, there is a greater need to integrate safety by design – from rigorous testing for adversarial robustness to implementing guardrails that align model behaviour with ethical and policy requirements.

ICLR 2025’s focus on safety underscores that future ML systems will be judged not only on performance, but on trustworthiness and safety robustness.

ICLR 2025 Discussions

Many fascinating discussions were about the potential impact of AI model collapse, attributed to insufficient human training and the use of iterations of LLM-generated text as inputs for subsequent versions of LLM models.

This conversation has paralleled emerging concept of ‘the Era of Experience’ introduced by David Silver and Richard S. Sutton’s paper suggesting that we are transitioning from the era of data to the era of learning from environment similarly to Reinforcement learning concepts of AlphaGo era.

Alongside these developments, the ICLR community has increasingly questioned the adequacy of current evaluation methods, noting that existing benchmarks tend to saturate too quickly and may not effectively reflect real-world challenges, emphasising the need for more sophisticated and realistic eval frameworks.

Conclusion

The research directions highlighted at ICLR 2025 paint a picture of an AI field striving for both greater capability and greater responsibility. Trends like agentic models and adaptive fine-tuning point toward AI that is more autonomous and flexible, able to handle open-ended challenges and continuously learn.

At the same time, the evolution of foundation models, concerns of AI model collapse and the emphasis on safety show a commitment to making these powerful frameworks more usable, reliable, and data selective. Overall, ICLR 2025 was a great opportunity for us to understand what to expect next in this ever-evolving field.