Our Code of Conduct
Our Responsible Business Practices
Anti-Bribery and Anti-Corruption
Why it matters
At NEOM, we recognize that bribery and corruption have the potential to divert resources, prevent development, and make societies less fair. Any acts of bribery or corruption would also damage our reputation, destroy stakeholder or investor trust and harm our ability to set a global example as ‘a new vision of what the future could be.’
We are therefore committed to a zero tolerance position on bribery or corruption in any form.
A bribe is anything that has a value to the person receiving it and that could be seen as an attempt to influence them into providing favorable treatment. Bribery is not just about cash. It could also include gifts, entertainment, charitable donations, or other favors.
Facilitation payments are another type of corrupt payment. They are (usually) small sums paid to public officials as a way of encouraging them to carry out their ordinary duties, or carry them out more quickly. This might be a payment made to a border official, for example, to obtain customs clearance in a shorter time than normal.
Our commitments
As a company, we are committed to:
- Implementing the highest standards of integrity and complying with applicable anti-bribery and anti-corruption laws and regulations
- Establishing and maintaining anti-bribery and anti-corruption policies and procedures that set out the guidance to be followed by employees in preventing, detecting, and responding to all cases of bribery and corruption
- Responding with disciplinary action, up to and including termination, when faced with cases of bribery or corruption, and referring relevant cases to the public authorities for criminal prosecution where appropriate
- Ensuring all charitable contributions made by NEOM follow strict procedures designed to prohibit donations that could be seen as an attempt to improperly influence others in our favor
- Reinforcing our anti-bribery and anti-corruption standards to all employees and third-parties, through training and communication, and ensure they are totally supported if they resist a request to pay a bribe
- Conducting regular risk assessments to monitor our exposure to bribery and corruption risks, helping us to ensure that we understand these risks and that the mitigations we have in place are sufficient
- Monitoring our relationships with public officials, and any lobbying activities in particular, to ensure that these interactions remain free from facilitation payments, inappropriate gifts and hospitality (see ‘Gifts and hospitality’ section) or any behavior that could be considered an attempt to gain an unfair advantage
- Assessing our third parties for bribery and corruption risks and ensuring third-party relationships are subject to additional due diligence, review, and approval where required
- Monitoring our third-party relationships through automated screening and daily adverse media checks to ensure that our understanding of relevant bribery and corruption risks is up to date
- Thoroughly investigating any cases of bribery and corruption reported to us, applying appropriate disciplinary measures to proven cases, and passing relevant cases to the public authorities where applicable
Our expectations
As NEOM representatives, we expect you to:
- Understand our zero tolerance stance against bribery and corruption of any kind, and help uphold our commitments in this area, by setting an example for others in ensuring you adhere to all applicable regulations and procedures
- Promote and uphold a culture of integrity at NEOM
- Never give, offer, or accept a bribe or corrupt payment of any kind, unless there is an imminent threat to your freedom or physical safety
- Follow all procedures designed to prevent charitable contributions from being used for corrupt purposes, if you are working in a related role
- Ensure our bribery and corruption commitments and the associated legal liabilities are communicated to our external partners, if you are working in a related role
Report any known or suspected cases of bribery or corruption
as soon as possible, by contacting your line manager, a senior member of the Compliance Department, or our Speak Up channel.
Talk to us
If you have any questions, or are unsure what could constitute a bribe or corrupt payment, speak to your line manager or a senior member of the Compliance Department.
Further Information
More information available in our:
However, you can also contact the Compliance Department with any queries or concerns you may have about bribery and corruption.
Conflicts of Interest
Why it matters
To maintain the trust and confidence of our stakeholders, we need to ensure we always make decisions in NEOM’s best interest. A conflict of interest is when our personal motivations conflict with NEOM’s best interests as a company. A conflict of interest can take many forms but situations that could lead to a conflict of interest include:
- Line managing a relative or family friend
- Making procurement decisions regarding companies from which you profit personally
- Making recruitment decisions regarding candidates to whom you are personally connected
- Taking on second jobs or outside activities whose aims are in competition with ours
- Accepting the offer of becoming a member of a board, or sitting as a member, without prior approval
It doesn’t matter if our intentions are good. Even a perceived conflict of interest can lead to accusations of unfairness, and even corruption, if not properly managed.
So, it’s essential for us to declare all conflicts of interest, or situations that might lead to a conflict of interest, as we seek to maintain a workplace based on trust, fairness, and transparency.
Our commitments
As a company, we are committed to:
Properly recording and managing any conflicts of interest declared to us, in order to help us mitigate the risk of any unfair treatment or undue influence occurring as a result
Acting with fairness and ensuring that everyone gets the same opportunities at NEOM regardless of their personal connections or relationships
- Protect our reputation and make all business decisions in the best interest of NEOM
- Avoid any situation or action that may lead to a potential or actual conflict of interest
- Never engage in outside activities or interests, such as second jobs, whose objectives compete with ours
Talk to us
If you have any questions or are unsure what could constitute a conflict of interest, talk to your line manager or a senior member of the Compliance Department.
Question & Answer
Wrong. It doesn’t matter if your intentions are good. If you get involved in the selection process and your friend’s daughter is hired, it could lead to the accusation that you influenced the decision-making in her favor. If your boss is asking you to help out with this selection process, you should notify them, or a senior member of the Compliance Department, that this could lead to a perceived conflict of interest. You may then need to be separated from any decision-making involving your friend’s daughter. However, this will help to keep our recruitment processes transparent and protect you from any accusation that you acted improperly.
Further Information
More information available in our:
However, you can also contact the Compliance Department with any queries you may have about conflicts of interest.
Gifts and Hospitality
Why it matters
Gifts and hospitality are often used by companies as a way of strengthening their relationships. However, they can also be seen as a way for companies to gain unfair advantage. At NEOM, we want to build relationships based on trust, integrity, and our vision of a new future unlike anything the world has seen before. Although we may sometimes be exposed to them in the course of our working lives, we believe in a responsible approach to gifts and hospitality, based on fairness and transparency.
Our commitments
As a company, we are committed to:
Ensuring that any exchange of gifts or hospitality in which we are involved is not conducted with the intention of receiving or providing an unfair advantage and does not exceed the thresholds specified in this Code without having first obtained the necessary internal approvals
Maintaining a central register allowing all gifts and hospitality to be transparently recorded and monitored
Conducting selective, risk-based monitoring of employee expenses in order to identify any lavish or excessive gifts or hospitality exchanged on the company’s behalf
Investigating cases in which gifts or hospitality are found to be undeclared, excessive, or exchanged with the intention of receiving or providing unfair advantage, and following up with appropriate disciplinary measures and any other liabilities
Our expectations
As neom representatives, we expect you to:
- Never accept gifts or anything of value that could be seen to affect your decisionmaking in relation to a third party, such as from current or prospective suppliers seeking to do business with us
- In certain circumstances, you may be able to accept low value gifts or ‘giveaways’ such as branded pens or coffee mugs or hospitality where:
- this does not influence your decisions
- the value of the gift or hospitality does not exceed SAR 400
- Never accept gifts in the form of cash or cash equivalents (e.g., shopping vouchers)
- Ensure any gifts or hospitality you offer are appropriate and in line with NEOM’s policies. This applies equally to gifts and/or hospitality given or received internally within NEOM
- Take particular care in your interactions with public officials, ensuring that these interactions are fully transparent, properly documented and do not involve any exchange that could be seen as an attempt to gain preferential treatment or unfair advantage. You are permitted to accept gifts presented to you on official occasions involving governmental bodies, as a matter of courtesy and/or protocol. Official occasions can include meetings between NEOM and any state bodies. Such gifts may not be in the form of cash, and must not exceed a cash equivalent value SAR 400
Record any gifts or hospitality you offer or receive in the course of your work on the Gifts and Hospitality Register found on the NEOM Disclosures Platform, so that these can be properly recorded and monitored.
Seek approval if any gift or hospitality you receive in the course of your work is over the value of SAR 400 in accordance with the Gifts and Hospitality Policy.
Question & Answer
Wrong. You should never accept anything of value that could be seen to affect your decision-making at NEOM, especially when this involves current or prospective suppliers seeking to do business with us. It doesn’t matter if your intentions are good. If you accept the voucher and then this supplier wins the tender, you could be accused of providing unfair preferential treatment in exchange for the gift. It also doesn’t matter that this gift didn’t come in the form of cash or items purchased by your contact. You should never accept gifts in the form of cash equivalents, including shopping vouchers. In this scenario, you should politely decline the voucher and point out to your contact that NEOM’s responsible business practices prevent you from accepting gifts from current or prospective suppliers during a tendering process. You should also record the offer of the voucher in line with the provisions of the Gifts and Hospitality Policy. If you still have any questions, you can speak to your manager or the Compliance Department.
Further information
More information is available in our:
However, you can also contact the Compliance Department with any questions regarding our approach to gifts and hospitality.
Countering Fraud
Why it matters
At NEOM, our ambitions cannot be realized without the trust of others. We therefore have a duty to earn that trust every day, by operating with integrity, transparency, and honesty in everything we do.
Fraud is any act of deception intended to achieve personal gain or cause loss to others. Examples of fraud at work include embezzlement, theft, falsifying of documents, and misuse of NEOM assets, such as computers.
Fraud, and fraudulent activities, have the potential to damage our reputation and therefore our ability to win the trust on which our long-term goals depend.
Our commitments
As a company, we are committed to:
- Promoting honesty, integrity, and a zero tolerance stance against fraud of any kind
- Adhering to all applicable laws and regulations in relation to fraud and fraudulent activities
- Establishing and maintaining an anti-fraud policy that is aligned with applicable laws and regulations and sets out the rules to be followed by employees in preventing, detecting, and responding to any instances of fraud
- Adopting appropriate segregation of duties in our accounting practices, to help reduce the risk of fraudulent activities going unnoticed due to collusion or the actions of individuals
- Thoroughly investigating any cases of fraudulent activity reported to us, applying appropriate disciplinary measures to proven cases, and passing relevant cases to the public authorities where applicable
Our expectations
As NEOM representatives, we expect you to:
- Promote a culture of integrity at NEOM where fraud in any form is not tolerated
- Understand our zero tolerance stance against fraud of any kind, and help uphold our commitments in this area, by setting an example for others in ensuring you adhere to all applicable regulations and procedures
- Ensure that all NEOM property, such as computers, phones, and other hardware, is protected from theft and only used for legitimate work-related purposes in NEOM’s best interests
Speak up!
Contact your manager, a senior member of the Compliance Department, or our Speak Up channel as soon as possible if you know or suspect that any fraudulent activity is taking place.
Further information
More information is available in our:
However, you can also contact the Compliance Department if you have any questions or concerns about fraud or potentially fraudulent activities within the company.
Fair Competition
Why it matters
At NEOM, we want to build relationships based on quality, transparency, and a shared vision of what the future could be. It is therefore essential that we maintain a healthy spirit of competition in our processes for selecting third parties. Anti- competitive practices are not only illegal, but they also have the potential to damage our reputation and our ability to achieve our goals by selecting the best possible partners to work alongside us.
Our commitments
As a company, we are committed to:
Fostering a spirit of healthy competition in our procurement practices, with the goal of ensuring that our relationships are based on fairness, integrity, and transparency
Ensuring we only engage with third parties that share our standards regarding fair competition
Upholding the integrity of our procurement practices and maintaining fairness in our treatment of third parties, allowing them to compete for NEOM’s business on a fair and transparent basis
Not tolerating any form of anti-competitive practices among our current or prospective third parties
Our expectations
As NEOM representatives, we expect you to:
- Understand our commitments to fair, honest, and transparent third-party selection processes, and ensure you always deal fairly with our third-party business partners and suppliers
- Help us to uphold these commitments by communicating them to existing and prospective third parties if you are working in a related position
- Handle confidential information with care, and never share confidential information regarding our existing or prospective partners with other third parties competing to work for us
Further Information
More information available in our:
However, you can also contact the Compliance Department if you have any questions or concerns about our approach to fair competition.
Accurate Books and Records
Why it matters
At NEOM, we believe in promoting honesty and integrity in everything we do. Without these crucial factors, we would be unable to win the trust we need to realize our big ambitions. This means committing to robust standards of precision and transparency, not only in our announcements to the media, but also in our daily maintenance of accurate books and records.
Our commitments
As a company, we are committed to:
Ensuring all transactions are clearly and accurately recorded in the necessary general ledgers and accounts, with no off- the-books accounts or transactions
Segregating our processes of record-keeping between various teams and team members, as per our delegation of authorities matrix, to help maintain accuracy and reliability
Ensuring all reports, documents, and communications disclosed to the public are full, fair, accurate, timely, and understandable
Our commitments
As a company, we are committed to:
- Do your part to ensure all NEOM’s books, records, accounts, and reports are true, accurate and complete
- Never falsify information or misrepresent material facts as you develop and maintain documents at work
- Cooperate fully if an auditor reviews your team’s financial statements or operations
Further Information
More information available in our:
However, you can also contact the Compliance Department if you have any questions or concerns about our approach to books and records.
Shareholder Reporting
Why it matters
NEOM is committed to acting in the best interests of its shareholder and creating sustainable shareholder value. A fundamental part of this process involves providing our shareholder with the timely, transparent, and accurate information it needs to make decisions.
Our commitments
As a company, we are committed to:
Providing our shareholder with relevant information about our regular activities and business, such as our financial performance, in a timely and accurate manner
Keeping our shareholder informed of any fundamental developments at NEOM, such as the activation of a new sector or region, or the announcement of a new strategy
Proactively seeking feedback and suggestions for improvement from our shareholder and ensuring that there are no limitations for our shareholder to access information related to NEOM
- Help us provide our shareholder with accurate information by maintaining accurate records of your work
- Never communicate company information to NEOM’s shareholder unless authorized to do so
- Cooperate where necessary with the General Secretariat, which is authorized to communicate with our shareholder on our behalf
Further information
More information is available in our:
However, you can also contact the General Secretariat if you have any questions regarding our approach to shareholder reporting.
Confidential Information
Why it matters
At NEOM, information and ideas are some of our most valuable assets. Ideas need time to grow. We therefore need to make sure we do not share ideas or information prematurely with others. When information is designated as confidential, it requires specific handling in order to ensure it does not set false expectations, affect our project launches, damage our reputation or impact negatively on our partners.
By confidential information, we mean all non-public information that may be harmful to NEOM or our stakeholders if disclosed.
Our commitments
As a company, we are committed to:
Maintaining policies and procedures to ensure that confidential information is handled appropriately and that employees understand their responsibilities in relation to these policies and procedures
Investigating all reported cases of confidential information being shared or handled inappropriately, and following up with appropriate disciplinary measures where necessary
Creating a robust cyber-secure environment to protect the confidential information we hold from unauthorized access or compromise (see ‘Cybersecurity’ section)
Protecting the confidential information of our third parties as if it were our own (see ‘Data privacy’ section)
Our expectations
As NEOM representatives, we expect you to:
- Do your part to help us ensure that confidential information is protected, by understanding our commitments and following all related approvals, policies, and procedures
- Take responsibility for the protection of any confidential information available to you and ensure it is not disclosed to any unauthorized person (inside or outside the company) or used for your own benefit, even after your employment with NEOM is over
- Seek advice from NEOM Legal if you have confidential information related to potential partnerships, acquisitions, or deals NEOM is working on, and are considering buying or selling securities in any of those companies
- Treat the confidential information of our partners as if it were our own, if you are working in a related role
Talk to us
Speak to your line manager or an appropriate senior colleague if you’re unsure what might constitute confidential information or how it should be handled.
Further information
More information is available in our:
However, you can also contact the Compliance Department if you have any questions or concerns about our approach to confidentiality.
Money Laundering, Terrorist Financing, and Sanctions
Why it matters
As we establish ourselves as a key economic player in the region, we have a duty to maintain visibility over our business relationships and transactions.
In particular, we need to be alert to the risks associated with money laundering, terrorist financing, and economic sanctions. Remaining vigilant to these risks will not only help us to ensure we comply with the law and regulations, but also to ensure we maintain a positive economic impact on the world around us.
Our commitments
As a company, we are committed to:
Meeting our obligations under all applicable national and international laws and regulations related to money laundering, terrorist financing, and economic sanctions
Implementing effective processes to identify and manage our exposure to risk in these areas and conducting regular testing of these processes to ensure they remain fit for purpose
Providing training and communication for employees in relevant positions regarding our money laundering, terrorist financing, and sanctions risks, and the processes we have in place to mitigate them
Conducting investigations in relation to any actual or suspected breaches of economic sanctions or applicable laws and regulations in the area of money laundering or terrorist financing
Our expectations
As NEOM representatives, we expect you to:
Understand our commitment to abide by all applicable laws and regulations related to money laundering, terrorist financing, and economic sanctions
Ensure you conduct the required training and follow our processes to identify and manage our exposure to risk in these areas, if you are working in a related role
Promptly report any money laundering, terrorist financing, or economic sanctions concerns to your line manager, an appropriate senior colleague, or our Speak Up channel
Speak up!
If you are aware of any actions or business decisions that go against our commitments in this area, you should use the Speak Up channels set out in the ‘Speaking up’ section.
Talk to us
Speak to your manager or an appropriate senior colleague if you have any questions regarding our commitments or approach to money laundering, terrorist financing, or economic sanctions.
Further information
More information is available in our:
However, you can also contact the Compliance Department if you have any questions or concerns regarding our approach to money laundering, terrorist financing, or sanctions.