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  <front>
    <journal-meta />
    <article-meta>
      <title-group>
        <article-title>Patterns for Semi-Automated Trustworthiness Risk Assessment of AI Systems in Cyber-Physical Environments</article-title>
      </title-group>
      <contrib-group>
        <contrib contrib-type="author">
          <string-name>Samuel M. Senior</string-name>
          <xref ref-type="aff" rid="aff0">0</xref>
        </contrib>
        <contrib contrib-type="author">
          <string-name>Steve Taylor</string-name>
          <xref ref-type="aff" rid="aff0">0</xref>
        </contrib>
        <aff id="aff0">
          <label>0</label>
          <institution>IT Innovation Centre, University of Southampton</institution>
          ,
          <addr-line>Southampton</addr-line>
          ,
          <country country="UK">U.K</country>
        </aff>
      </contrib-group>
      <pub-date>
        <year>2025</year>
      </pub-date>
      <abstract>
        <p>With the use of AI systems growing, particularly in areas that can significantly efect people, trustworthy AI is needed. For this, transparent and accountable trustworthiness risk assessment of AI systems is required. The work here details an initial approach to trustworthiness risk assessment of AI systems that builds on a semi-automated risk assessment tool called Spyderisk and uses information from frameworks and other sources to guide it. AI systems are becoming increasingly prevalent, with increased adoption and use across industries informing or making decisions that afect more and more people in impactful ways. Diferent stakeholders of AI systems, as well as the people they afect, need to be able to trust them to behave in a correct, fair, and appropriate manner. That is, AI systems need to be trustworthy, where risks in the AI system, and in the wider system it is deployed, must be understood so that unacceptable risks can be managed and mitigated, leaving acceptable residual risks. This process must be transparent so that diferent stakeholders across the AI lifecycle can understand the risks and mitigations in place. For this, risk assessment is needed. The aim of the work here is to introduce an approach being developed for the semi-automated trustworthiness risk assessment of AI systems. This approach enhances a preexisting knowledge-based semi-automatic risk assessment tool developed by the University of Southampton, Spyderisk [1, 2], to expand its knowledge base from the cyber-physical domain to also include AI systems. The approach taken here is to use sources of information such as AI risk management and best practices frameworks. This then improves the adoptability and enhancability of this approach whilst also giving it a rigorous foundation. The ENISA Multilayer Framework for Good Cybersecurity Practices (FAICP) [3] and the NIST Artificial Intelligence Risk Management Framework (AI RMF) [ 4] are considered and discussed in the following subsection. Then Spyderisk is introduced. After, a mapping between these frameworks and Spyderisk is established. Finally, initial AI domain Spyderisk knowledge extensions are detailed.</p>
      </abstract>
      <kwd-group>
        <kwd>eol&gt;trustworthy AI</kwd>
        <kwd>AI risk management</kwd>
        <kwd>semi-automated risk assessment</kwd>
      </kwd-group>
    </article-meta>
  </front>
  <body>
    <sec id="sec-1">
      <title>1. Introduction</title>
      <p>
        1.1. The ENISA FAICP and NIST AI RMF
The FAICP [
        <xref ref-type="bibr" rid="ref3">3</xref>
        ] applies the OECD definition of AI [
        <xref ref-type="bibr" rid="ref5">5</xref>
        ] and highlights the need for AI-specific practices
in cybersecurity and a lifecycle perspective on AI trustworthiness. It is structured in three layers
reflecting diferent aspects of good AI cybersecurity practices: Cybersecurity foundations, AI-specific
cybersecurity practices, and sector-specific considerations. The ENISA framework covers risks directly
related to the AI system as well as its socio-technical environment.
      </p>
      <p>Within it, AI systems are defined to have desired characteristics that contribute to the trustworthiness
of the AI system. This AI trustworthiness is “the confidence that AI systems will behave within specified
norms, as a function of some characteristics [. . . ]”. The diferent characteristics of AI trustworthiness
considered are: Accountability, Accuracy, Explainability, Fairness, Privacy, Reliability, Resiliency,
Robustness, Safety, Security, and Transparency. These AI system characteristics are classified as
technical, socio-technical, and guiding principles.</p>
      <p>
        The FAICP recommends the ISO 2700x standards [
        <xref ref-type="bibr" rid="ref6">6</xref>
        ], NIST AI RMF [
        <xref ref-type="bibr" rid="ref4">4</xref>
        ], and ENISA’s best practices
for controls in the risk management of general-purpose AI. It highlights that for practices reflecting the
characteristics of the socio-technical and environment and sector-specific requirements, fragmented
recommendations, best practices, solutions, and tools may be stumbling blocks for sectoral stakeholders,
and that collaboration and information sharing on sector-specific issues and mitigations between
sectoral stakeholders is needed.
      </p>
      <p>
        The NIST AI RMF [
        <xref ref-type="bibr" rid="ref4">4</xref>
        ] supports the management of AI risks and fosters trustworthy and responsible
AI. The AI RMF applies the OECD [
        <xref ref-type="bibr" rid="ref7">7</xref>
        ] and the ISO/IEC 22989 [
        <xref ref-type="bibr" rid="ref8">8</xref>
        ] definitions of AI, highlighting a lifecycle
perspective on AI trustworthiness. Risk management in the AI RMF is based on adaptations of risk
management and assessment definitions from ISO 31000 [
        <xref ref-type="bibr" rid="ref9">9</xref>
        ], and aims to identify both opportunities
and threats within the system. The AI RMF acknowledges that some AI risks may be dificult to
quantitatively measure but may nevertheless be relevant.
      </p>
      <p>The AI RMF identifies a set of trustworthiness characteristics that address technical, socio-technical
and ethical / legal aspects of the AI system. These are Safe, Secure and Resilient, Explainable and
Interpretable, Privacy-Enhanced, Fair - With Harmful Bias Managed, Valid and Reliable, and Accountable
and Transparent. Valid and Reliable is a necessary condition of trustworthiness, and Accountable and
Transparent relate to all the other characteristics. A trustworthy AI system requires balancing these
characteristics within its specific context of use, which may entail trade-ofs.</p>
      <p>The AI RMF argues that AI risk management should be incorporated into the broader risk management
surrounding an AI system, considering also its environment and relevant actors. To support the risk
management process, an RMF core is proposed that includes four functions – Govern, Map, Measure,
and Manage – which are described at a process level. As such, the AI RMF gives a comprehensive
non-prescriptive framework for organisations working with AI systems.</p>
      <p>The FAICP and AI RMF have similar definitions and considerations of the socio-technical context
of the system. The layered approach of the FAICP addresses the ICT infrastructure, the AI system
itself, and the system within a given sector or socio-technical environment. The four-function approach
of the AI RMF maps out, measures, and manages the risks of AI, whilst maintaining governance
throughout. The FAICP categorises AI threats into types of attacks whilst the AI RMF categorises AI
harms into broad categories based on harms at the person-, organisation-, or ecosystem-level. The
FAICP identifies 11 trustworthy characteristics of an AI system whilst the AI RMF identifies seven AI
trustworthy characteristics. These seven are broader though fit within the FAICP’s 11. Both frameworks
complement each other and provide guidelines and methodology. As such, an implemented approach
to AI risk assessment can be formed from both of these.</p>
    </sec>
    <sec id="sec-2">
      <title>2. Spyderisk for Risk Assessment and Management</title>
      <p>
        Spyderisk is a semi-automated asset-based risk assessment and management tool following the ISO
27005 [
        <xref ref-type="bibr" rid="ref10">10</xref>
        ] risk assessment methodology which uses a knowledge base containing relevant domain
information. Within it, a user builds a model of their system under test (SUT) and the engine uses logic
and inference with the encoded information of the knowledge base to determine the threats and risks
present in the SUT and calculate their likelihoods, along with the threat paths that form due to threats
cascading from one to another. The core concept is shown in Figure 1. It is comprised of three main
parts: a knowledge base that contains and encodes domain-specific information, a GUI frontend that is
used to model and view a given system, and a validation and risk calculation engine.
      </p>
      <p>Within a risk calculation, Spyderisk automatically identifies the threats and risks present in a system,
along with their likelihoods. The threat and risk likelihoods are calculated using an automated iterative
algorithm that considers how entry point threats propagate to further threats in the system, and how
all these threats can cause further threats, and so on. Initial input values are given to represent how
much diferent components can be trusted or expected to behave correctly, and these are then used to
inform the initial likelihoods of threats in the system. As threats propagate through the system, the
likelihoods of other threats increase based on these, if a new cause is more likely than the current cause.
This iterative algorithm converges when threat and risk likelihoods stop increasing. This automated
approach is advantageous to manual risk calculations as there can be many threats and risks in a system,
and manual risk calculations may only consider a subset of them, and may not fully consider their
propagation to further threats and risks.</p>
      <p>
        The Spyderisk schema is shown in Figure 2, adapted from [
        <xref ref-type="bibr" rid="ref12">12</xref>
        ]. Here, there are no new classes
introduced compared to previous Spyderisk work and whilst the trustworthiness characteristic, impact,
likelihood and human trustor elements have been explicitly included, these are pre-existing to Spyderisk
and just their explicit representation in this schema is new, improving clarity. This schema is derived
from several risk assessment patterns, predominantly the ISO 27000 series on information security
risk management [
        <xref ref-type="bibr" rid="ref6">6</xref>
        ], but also includes aspects, such as safety, derived from risk management in other
domains (e.g. medicine), where safety is an important factor. In line with ISO 27005 [
        <xref ref-type="bibr" rid="ref10">10</xref>
        ], Spyderisk
concerns system Assets and the Consequences that may occur if those Assets are exposed to Threats.
Here, a Consequence that has a negative impact is a Harm.
      </p>
      <p>The Spyderisk knowledge base encodes threats, assets, consequences, and controls for a given domain.
It is a generalised abstraction such that it is not so specific to one system that it cannot be used for
others within the given domain. Prior to the work here, the knowledge base contained knowledge
primarily on the cybersecurity of cyber-physical systems. This knowledge already has relevance to AI
systems, e.g. with it containing assets like software processes, ICT hardware, data, computer networks,
people, places and jurisdictions. The contribution of the work here is to extend this knowledge base
to include assets, threats, consequences, controls, and trustworthiness characteristics inherent to AI
systems.</p>
      <p>This knowledge extension follows a three-step process of knowledge acquisition, translation, and
encoding. Knowledge acquisition includes locating sources of knowledge, accessing their relevance, and
collating their knowledge; with key considerations of what are important assets, threats, consequences
and harms to model, among others. Knowledge translation involves translating the acquired knowledge
into the format of the Spyderisk knowledge schema, through determining what can be modelled as assets,
threats, consequences, trustworthiness characteristics, controls, etc. Knowledge encoding involves
the practical steps of encoding the new knowledge into the Spyderisk knowledge base. Through this
knowledge extension, Spyderisk will be able to perform automated risk assessment of AI systems and
its wider ICT system.</p>
      <p>
        Spyderisk already has extensive encoded knowledge regarding computer processing, data storage
and usage, ICT hardware, networking, plus a significant amount in human and social aspects such
as human roles, rights (focusing on privacy), institutions, physical spaces and regulation. It contains
cybersecurity-related threats and controls, the consequences of these threats on diferent asset types,
and how these threats can propagate through systems made of these asset types. Spyderisk is discussed
in detail in [
        <xref ref-type="bibr" rid="ref2">2</xref>
        ]. The novel contributions of the work presented here is the extension of the Spyderisk
knowledge base towards risk assessment of AI components and the wider systems in which they sit
through the addition of AI trustworthiness, risks, and harms. There are cross-domain interrelationships
that are also encoded, reflecting complexities in real-world situations where AI systems are deployed
and used. Examples of these are as follows.
      </p>
      <p>• AI models reading data as input, writing data as output, running on ICT hardware, communicating
over computer networks, and interacting with people.
• Cybersecurity threats afecting AI quality / accuracy / robustness / fairness.
• Inaccurate AI models afecting the data output from said AI models.
• AI models unknowingly exposing personal information, compromising the privacy of citizens.
• Cybersecurity controls, e.g., reducing risks of unauthentic training data for AI models.</p>
      <p>These are initial examples that illustrate diferent cause and efect relationships between the domains.
Patterns such as these have been considered in the knowledge extension and a key observation made
so far is that data is a key link across domains, due to the multiple forms it can take. E.g., it is used for
AI training, so compromises in training data afect the model results, which is also data.</p>
      <p>The FAICP and AI RMF are mapped to the Spyderisk modelling process next. This enables the
Spyderisk approach to AI risk assessment to follow, and be compatible with, the FAICP and AI RMF,
giving it a rigorous foundation and easier adoptability.</p>
    </sec>
    <sec id="sec-3">
      <title>3. Mapping the FAICP and AI RMF to Spyderisk</title>
      <p>The FAICP and AI RMF identify sets of AI trustworthiness characteristics, harms, threat types, and
controls. In terms of AI trustworthiness characteristics, in the work here, an initial focus is given on
accuracy, and fairness. Additionally, the FAICP identifies a general set of AI assets that may be present,
grouped into categories including data, models, stakeholders, processes, and environment. Assets
within these categories already exist in the Spyderisk knowledge base, making the integration and
cross-domain interrelationships easy to implement as there is already good coverage of cyber-physical
threats and risks for these AI asset categories.</p>
      <p>The FAICP and AI RMF have diferent but compatible approaches. The FAICP considers risk
management in a three-layer manner. Each layer builds up from the prior layer, where the first covers the
cybersecurity foundations, the second covers AI-specific cybersecurity practices, and the third considers
best practices for the sectoral context of where the AI system will be deployed. The FAICP three-layer
approach is compatible with Spyderisk, since, for a user modelling a system in Spyderisk to produce a
correctly functioning system model, they must specify the cyber-physical system components. This
means the user will inherently model the ICT infrastructure of the first layer. The second layer of the
FAICP is sector-agnostic AI risk management and provides requirements for threats, risks and controls
specific to AI, which will be covered by the knowledge extensions. For the sector-specific third layer,
some sector-specific AI threats may be encoded, and the modeller of a system will adjust consequence
impact levels related to key parts of the sector-specific AI system. These impacts afect the risk levels,
so sector-critical risks are highlighted and prioritised.</p>
      <p>The four functions of the AI RMF are compatible with Spyderisk: Governance is addressed through the
risk assessment of Spyderisk, helping towards the accountability, transparency, and reporting structures,
as well as making risk assessment more accessible to non-experts. Map is addressed through the
Spyderisk system model creation and risk assessment, with this giving the context of risks concerning
the AI system. Measure is addressed through the calculated likelihood and risk levels for threats and
consequences identified through the automated risk assessment calculation, aided through the setting
of impact levels to highlight important consequences and the setting of controls to mitigate threats and
risks. Additionally, Spyderisk evaluates risks stemming from compromises of trustworthy characteristics
of the AI system. Through repeating the risk assessment over the lifecycle of the AI system, identified AI
risks can be tracked over time, furthering the Measure function. Finally, for Manage, the risk assessment
provides and recommends controls that address identified threats and risks.</p>
      <p>The FAICP and AI RMF have a large focus on the compromise of AI trustworthiness characteristics,
actions to reduce the likelihoods of these compromises occurring, transparent reporting of AI risks, and
accountability for the actions and decisions made regarding them. Both also focus on the lifecycle of
the AI system and surrounding ICT system, from design to deployment, and its evolution over time.
The user of Spyderisk being required to explicitly model the cyber-physical system and AI-system
components means the full cyber-physical socio-technical context of the AI system and associated ICT
system is included within the Spyderisk system model. As such, the ICT context the AI system is in and
the AI system as a socio-technical system are both inherently considered within Spyderisk.</p>
      <p>Spyderisk can also be used throughout the lifecycle of an AI system. At the design stage it can assess
potential risks to pre-emptively mitigate them and during the lifetime operation of the system it can
assess risks using external information to adjust metrics related to vulnerabilities as the system operation
evolves. Additionally, diferent hypothetical scenarios can be tested. All these lead to the optimisation of
AI system trustworthiness characteristics through testing diferent optimisation scenarios and exploring
their risks so that trade-ofs to these optimisations are known, understood, and planned for before any
changes are made to the real-life system, allowing for informed decisions to be made and the most
appropriate set of optimisations for a given system and context to be chosen. The importance of this is
highlighted by the FAICP, which points out that optimisation of some trustworthiness characteristics can
negatively afect others, resulting in trade-ofs. With links between the FAICP, AI RMF, and Spyderisk
mapped and understood, knowledge can now be encoded within the Spyderisk knowledge base.</p>
    </sec>
    <sec id="sec-4">
      <title>4. Spyderisk Knowledge Extensions for Trustworthy AI Risk</title>
    </sec>
    <sec id="sec-5">
      <title>Assessment and Optimisation</title>
      <p>
        The initial work towards knowledge modelling of AI-related assets, threats, harms, consequences for
Spyderisk contains essentials needed to model ML-based harms resulting from compromises of integrity
or fairness of training data, or the actions a malicious user of an ML model. Knowledge has been
elicited primarily from the FAICP [
        <xref ref-type="bibr" rid="ref3">3</xref>
        ] and the AI RMF [
        <xref ref-type="bibr" rid="ref4">4</xref>
        ], as well as A Taxonomy of Trustworthiness
for Artificial Intelligence [
        <xref ref-type="bibr" rid="ref13">13</xref>
        ], Ethics guidelines for trustworthy AI [
        <xref ref-type="bibr" rid="ref14">14</xref>
        ], Securing Machine Learning
Algorithms [
        <xref ref-type="bibr" rid="ref15">15</xref>
        ] and AI Cybersecurity Challenges - Threat Landscape for Artificial Intelligence [
        <xref ref-type="bibr" rid="ref16">16</xref>
        ].
An initial set of key concepts has been determined that model an AI system over its lifecycle, shown in
the high-level schematic of Figure 3.
      </p>
      <p>"ML Model" and "Training Algorithm" are subtypes of software process and the training, testing,
validation, hyperparameters, model parameters, inputs, and predictions data are all subtypes of data.
Here, software processes run on hardware, can consume data as input, and produce data as output.
Data can be related to a software process, stored within databases and filesystems on ICT hardware,
and transmitted over computer networks. Data can also link to humans, e.g. humans interact with
data via software processes or the data being personal data relating to a person as a data subject.
The Process and Data parent types already exist in the Spyderisk knowledge base, meaning there are
already cybersecurity-related threats applicable to these AI system components, providing a point of
integration between the domains of cybersecurity and AI. The links between the diferent assets in this
ifgure represent relationships between them, showing how they interact with or use each other. These
assets and relationships enable a user of Spyderisk to construct models of an AI SUT that encompasses
diferent phases of the ML lifecycle, since the creation of the ML model as well as its usage is included.</p>
      <p>As mentioned, Figure 3 is a high-level schematic of an ML system that encompasses both the
training and deployment phases of the system. The top half represents the training phase(s), where
training data is used to determine the model parameters, testing data is used to test the model accuracy,
hyperparameters are used to define the training process, and validation data is used to guide the
hyperparameter values. The bottom half represents the usage phase, where input data is received by the
ML model, which, in conjunction with the model parameters, outputs predictions based on this input.
These then enable diferent system models to be constructed, which can include ML model creation via
training, ML model operation, or the two combined, which can be in a continuous training and usage
cycle. This means that in these models, issues in one phase can propagate to afect the other.</p>
      <p>
        With the schematic defined, it can be used to determine matching patterns for threats that could
occur in an ML system. Here, a matching pattern is a specification of assets and relationships required
Equality and equity are represented within the data, with
issues such as harmful bias and discrimination managed [
        <xref ref-type="bibr" rid="ref4">4</xref>
        ].
      </p>
      <p>Fair Processing</p>
      <p>Loss of Fair Pro- Process Inputs are processed such that resulting outputs have equality
cessing and equity, are not unduly detrimental, and do not contain
harmful bias and discrimination.</p>
      <p>Accuracy</p>
      <p>Loss of Accuracy</p>
      <p>Data</p>
      <p>
        “Correctness of output compared with reality.” [
        <xref ref-type="bibr" rid="ref3">3</xref>
        ]
to be present for the threat to occur, plus a trustworthiness characteristic at an asset that causes the
threat when it becomes compromised, and a consequence at an assets that is the efect of the threat.
Additionally, the trustworthiness characteristics and consequences in these matching patterns can be
from the cyber-physical domain as well as the AI-domain, thus allowing these threat patterns to bridge
between these two domains when threats contain ones from either. Spyderisk determines the presence
of threats in a system model through the use of matching patterns.
      </p>
      <p>An example matching pattern is shown in Figure 4. The pattern is denoted by the Asset types
("Training Algorithm" and "Training Data") and the relation between them (“usesToTrain”), is caused
by the Training Data losing integrity, and results in the Training Algorithm being unreliable.</p>
      <p>For ML-related threats, the asset types and relationships in Figure 3 determine the prototype elements
from which the matching patterns are constructed. In this initial work, the focus is on the accuracy
and fairness trustworthiness characteristics of the ML model predictions and how compromises of
other trustworthiness characteristics in the system can lead to these, where these compromises may
propagate through the system and directly or indirectly afect other assets of all kinds (e.g. people,
institutions, downstream processes). Trustworthiness characteristics and consequences new to the
Spyderisk knowledge base have been identified and encoded within it to allow new threats to be defined.
These new trustworthiness characteristics and consequences are given in Table 1.</p>
      <p>Using these and the asset types and relationships in Figure 3, threats have been encoded to model
how training data that become incorrect (unintentionally or maliciously) propagate through the system
to eventually afect the accuracy and fairness of model predictions, along with training data being unfair
or biased as well. This considers threat paths from the training data to the training algorithm, model
parameters, ML model, and ML predictions. Malicious users have also been modelled that maliciously
alter the inputs to the ML model, afecting the accuracy and fairness of the model predictions.</p>
      <p>Each ML-related threat is encoded independently inside Spyderisk and together, along with other
cyber-physical threats, they automatically form chains of threats in the semi-automated risk calculation
of Spyderisk. This is due to the consequence of one threat being the cause of another, leading to chains
forming as threats and risks propagate through a system. One such chain of threats is given in Figure 5.</p>
      <p>Here, there are four threats connected together in a chain. The block boxes represent assets that
must be present for the threat to occur, and the block arrows between them represent the relationships
that must be present between them. The red boxes represent trustworthiness characteristics that trigger
the threat when they become compromised, the red ovals represent consequences of threats occurring,
and the green oval represents a control that would block the threat. The yellow arrows show how one
threat chains to another, with the consequence of one becoming the cause of another. This chain of
threats shows how training data losing integrity causes the training algorithm to lose reliability, since
its outputs now will not be correct due to incorrect inputs. This then causes the model parameters to
lose integrity since the training algorithm is creating them based on incorrect training data. This leads
to the ML model being unreliable as its model parameters are incorrect. Finally, this leads to the ML
model predictions being inaccurate as its model parameters are incorrect. This chain may be broken
and the final threat not reached if the model is validated and the incorrect parameters detected.</p>
      <p>Multiple ML-related threats have successfully been encoded in the Spyderisk knowledge base, covering
aspects of fairness and accuracy of the ML system, with threat chains like this formed.</p>
    </sec>
    <sec id="sec-6">
      <title>5. Conclusions</title>
      <p>An approach and initial work towards trustworthiness risk assessment of AI systems has been given.
This approach builds on and enhances the existing Spyderisk risk assessment tool by extending its
knowledge base to AI trustworthiness, threats, risks, assets, and controls.</p>
      <p>Key source material has been examined and compared to Spyderisk, primarily the FAICP and AI RMF.
It has been concluded that these are compatible with Spyderisk and so the knowledge extensions to
it can use both these as sources of information and also be guided by them. This source material has
provided an initial set of assets, threats, consequences, and trustworthiness characteristics that model
ML threats and risks that has been encoded in the Spyderisk knowledge base. This has then integrated
this new knowledge with existing knowledge in the realm of ICT hardware, software, data, networks,
human interaction, physical spaces, cybersecurity and human rights such as privacy. This gives an
initial crossing of the domains of cyber-physical systems and AI systems, allowing threats and risks
from one to afect the other.</p>
      <p>The knowledge extension is ongoing work and additional information in the sources already
considered will be included in the knowledge base, along with information and considerations from additional
sources to be examined, such as ISO/IEC 23894:2023, as well as relevant regulation such as the EU
AI Act. The aim of this further work is to include more assets, threats, controls, consequences, and
trustworthiness characteristics in the Spyderisk knowledge base so that it has greater fidelity regarding
AI trustworthiness risk assessment and encompasses more of the AI trustworthiness characteristics
defined in these diferent sources. Additionally, a further aim is to include other types of AI system in
the Spyderisk knowledge base, rather than just ML systems.
This paper has been adapted from the D2.1 THEMIS 5.0 Methodological Framework and
Requirements Analysis deliverable report of the “Human-centered Trustworthiness Optimization in
Hybrid Decision Support” (THEMIS 5.0) project (https://www.themis-trust.eu/_files/ugd/a245c2_
9b7d6e7394b246f5921375833483b3a7.pdf), funded by the European Union’s Horizon Europe research and
innovation programme, Grant Agreement No. 101121042. Views expressed are those of the authors.</p>
    </sec>
    <sec id="sec-7">
      <title>Declaration on Generative AI</title>
      <p>The author(s) have not employed any Generative AI tools.</p>
    </sec>
  </body>
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