The Code applies to all NEOM board members, committee members, executive management, employees, subsidiaries, whether directly or indirectly owned, subsidiary employees, independent contractors, suppliers, and anyone who does business with NEOM (we’ll just use ‘NEOM representatives’ from now on).
Throughout this Code, we will use words like ‘we,’ ‘us’ and ‘our’ to refer to NEOM as a company. When you see words like ‘you’ and ‘your,’ we are addressing you as NEOM representatives directly.
We will use question and answer (Q&A) boxes, throughout the document, as a way of showing you some of the real-life scenarios in which our Code of Conduct should be applied.
All NEOM representatives are required to understand our commitments and follow our expectations as set out in this Code.
We also have additional documents in place for specific NEOM representatives. Additional expectations for board members are set out in our Governance Manual; and additional expectations for suppliers, as well as anyone doing business with NEOM, are set out in our Supplier Code of Conduct. Our subsidiaries, whether directly or indirectly owned, are also bound by the Subsidiary Governance Policy, which places additional responsibilities on our subsidiaries to enable the whole group to meet our conduct standards.
Failing to meet these expectations could result in investigation and disciplinary measures in line with our associated procedures. Any exception to the standards and expectations set out in this Code must be presented to the Compliance Department and approved by the Board.
We recognize that our Code won’t provide you with the answer to every question.
However, it will provide you with a summary of our commitments and expectations, as well as a ‘map and compass’ to help guide you toward more information and points of contact where necessary.
We want to empower you to confidently make the best decisions as quickly as possible. So we want to make this Code easy to approach and use. Look out for the ‘Further information’ headings within the document, which point out the additional documents and contacts you might find useful. These resources are then listed fully in the ‘Further Information and Resources’ section at the back.
Using this information, you can ask yourself the following questions, when deciding whether or not to take a certain course of action in your working life:
Is it legal?
Does it align with our Code and our Values?
Does it align with our policies?
Would it reflect positively on NEOM if it came out in the media?
If the answer to all these questions is ‘Yes’ – then, go for it! However, if the answer to any of these questions is ‘No,’ you should avoid that course of action, or talk to our Compliance Department. You should also speak to the Compliance Department if your answer is “I’m not sure” or if any part of this Code is unclear to you.
As well as the Compliance Department, you can also speak to your line manager, your People Business Partner, or an appropriate senior colleague from another department. This Code will help guide you to the best point of contact for your query.
If you have a more serious concern, or would like to speak to someone anonymously, our ‘Speaking up’ section will show you how you can do this as well.
We all have a responsibility to follow the principles set out in this Code of Conduct – but if you’re a manager at NEOM,* you also have some additional responsibilities.
As managers, it’s part of your role to serve as an example, and a source of guidance, to your team members on the day-to-day issues that our Code of Conduct covers. In this section, we’ll set out what we mean by this, and how NEOM commits to support you in this role.
*By ‘manager’ we mean anyone to whom individuals or teams report as part of their work. This could include line managers, team leaders or supervisors, as well as more senior staff members.
We will stand by our managers in any decision they make that is in line with our Code of Conduct – we understand that the right decision isn’t always the easiest one
We will also listen to the concerns of our managers regarding any behavior, by their team members or fellow managers, that goes against this Code of Conduct
Finally, we commit to empower our managers with any support they need to fulfil their additional responsibilities in relation to our Code of Conduct set out in the following pages
Set a clear example, by upholding our Code of Conduct’s principles in your daily working life
Act as an ambassador for our Values, making sure you embody them in your leadership behaviors and can provide others with guidance on how to be a role model to do the same
Be familiar with our Code of Conduct, so that you can act as a point of contact for any related questions from your team members or fellow managers
Talk about our Code of Conduct with your team members, to ensure they understand its expectations
Challenge any behavior you see which goes against our Code of Conduct – not only among your team members but also among your fellow managers too
Be accessible and listen to any team members with concerns about the conduct of their colleagues or other managers
Respond as soon as possible to any concern raised (and don’t forget to thank the person who raised it – the decision to speak to you may not have been an easy one)
And finally, just ask! We don’t expect our managers to have the answer to every question. So, it’s important that you seek advice from senior colleagues or escalate concerns when the best course of action isn’t clear to you. Your management colleagues in the Legal, People and Compliance departments, for example, are on hand to act as a point of contact for any relevant questions or concerns
Wrong. At NEOM, we don’t expect our managers to know the answer to every question. But we do expect managers to ask an appropriate senior colleague if they are unsure how to respond to queries from their team – especially if these queries relate to our Code of Conduct. If you’re unsure of how to reply to your team member regarding any potential conflict of interest, you should thank them for raising the concern, then ask a colleague in our Compliance Department for advice before responding.
At NEOM, we want to create a place that is exceptional. In order to achieve this bold vision, we also need to create a great place to work. We need your support to create a culture of integrity, where anyone at NEOM feels confident in raising any concern if they feel something isn’t right. If you know of, or suspect, any behavior that goes against this Code of Conduct, our Values, our policies, or applicable laws and regulations, we need you to ‘Speak up.’ Working together, we can build a place that everyone is proud to be a part of
As a company, we are committed to:
Creating an open culture where all employees feel comfortable reporting unacceptable behaviors
Not tolerating retaliation against anyone who reports a concern in good faith (if a report is made in good faith, it means the report is sincere and made in the best interests of NEOM, rather than for personal gain)
Raising awareness of the various ways NEOM representatives can report a concern
Speak up! And tell us as soon as possible if you have any concerns about potential breaches of applicable laws and regulations, this Code of Conduct, our policies, or NEOM’s Values
Report any retaliation against anyone who raises a concern using our Speak Up channel
As an organization, we are committed to transparency. If you raise a concern as part of the Speak Up process, you will receive a guidance note setting out what to expect during and following any investigation resulting from having raised your concern. For reference, this guidance, known as ‘What to Expect During a Speak Up Matter’, can be found on the Speak Up channel.
In most circumstances, the right thing to do is to talk to your manager. However, if you don’t feel able to do this, you can also contact the Compliance, Legal or People departments.
We are committed, as part of our Speak Up program, to protect the confidentiality of anyone raising a concern. Our Speak Up channel will offer you the option to make a report anonymously. However, it’s important to remember that anonymous reporting is only an option. If you feel comfortable providing your name, we can take action faster and more effectively.
As long as your report is made in good faith, we will protect you from any form of retaliation – even if your concern turns out to be unfounded.