Our Code of Conduct
Our Technology
Responsible Innovation and Use of Technology
Why it matters
NEOM is being designed with a focus on innovation and technology. As a hub for innovation, entrepreneurs, business leaders, and companies will come to NEOM to research, incubate, and commercialize new technologies and enterprises in ground- breaking ways.
With this unprecedented technological potential comes a duty to ensure that all our innovations are not just achieved, but achieved responsibly. The commitments that follow set out what we mean by this.
As pioneers, we understand that we are operating on the frontiers of what is technologically possible. Although we are therefore often working in an unpredictable environment, our commitment to acting ethically and to responsible innovation and use of technology remains a constant.
Our commitments
As a company, we are committed to:
- Using our innovations to meet the most pressing global challenges of our time, for example by developing smart, technology-driven climate solutions for local implementation and global export
- Developing human-centered technologies that not only enhance livability but also enable residents and visitors to reduce their negative environmental impact
- Allowing NEOM residents to become participants in the development of new technologies, by establishing ourselves as a ‘living laboratory’ in which the life-changing technologies of the future can be pioneered
- Developing clean technology screening criteria to ensure our technological developments don’t impact negatively on the environment
- Continuously seeking new technologies and advancements that enhance the safety of all those who choose to live and work with us (see ‘Promoting safety’ section)
- Developing the world’s most advanced ‘cognitive city,’ by acting as responsible stewards of personal data and using data-sharing to produce positive outcomes that change the way we live (see ‘Data privacy’ section)
- Ensuring all projects involving artificial intelligence (AI) are developed responsibly and used to generate positive human-centered outcomes, such as AI-enabled medical diagnostics
Our expectations
As NEOM representatives, we expect you to:
- Walk the talk, by maintaining the highest standards of integrity, robustness, objectivity, and transparency in all innovations and collaborations with external partners
- Understand our commitments to responsible innovation and use of technology, and speak up if you encounter any actions or business decisions that go against them
- Ensure that accurate records of our research are maintained, showing how our research has been conducted and used to inform our decisions
- Never collaborate with third parties on new innovations or technologies without the necessary approvals
- Never speak publicly or to third parties about developing innovations or technologies that have not yet been approved for external communication
- Ensure relevant partners understand and follow our commitments on responsible innovation and use of technology, if you are working in a related role
- Ensure that any invention, composition, or other form of intellectual property you create as part of your employment at the company is registered to NEOM
Talk to us
If you have any questions or concerns regarding our commitment to responsible innovation and use of technology, please talk to your line manager, or a member of the Compliance Department.
Further Information
More information available in our:
You can also contact the Compliance Department with any questions regarding our approach to responsible innovation and use of technology.
Cybersecurity
Why it matters
As drivers of world-leading innovation, technology is at the heart of everything we do. Cybersecurity is how we protect our technology from unauthorized access and compromise.
- Maintaining the highest standards of cybersecurity, in line with all applicable national and sector-specific regulations, as well as relevant international standards and leading practices
- Creating a cyber-secure environment by putting in place security measures that reduce the risk of a successful cyberattack on us and provide a coordinated response to any incidents
- Empowering NEOM representatives to uphold our cybersecurity standards by raising their awareness of relevant threats and how these can be prevented
- Requiring third-party suppliers to provide reasonable assurance of their ability to adhere to our relevant cybersecurity requirements
- Embedding cybersecurity into our entire service life cycle to ensure that compliance is continuous
Our expectations
As NEOM representatives, we expect you to:
- Beware of phishing and other kinds of ‘social engineering’ designed to trick you into making cybersecurity mistakes, for example by clicking on links or opening attachments from seemingly legitimate sources
- Use appropriate password protection for any files containing sensitive business data, ensuring passwords are secure and regularly updated in line with the guidance set out in our password policy
- Avoid sending external emails containing confidential or sensitive information, and never use cloud storage services to store, alter or exchange company information without the required permissions
- Install only approved software on NEOM devices and ensure the latest security updates are applied to any software being used on our system
- Understand that remote working brings additional cybersecurity challenges and follow all related guidance in our IT Policy when using NEOM devices off-site
- Never use personal email accounts to exchange company information with third parties or forward company related emails to a personal account
- Inform your line manager immediately if you encounter or suspect a cybersecurity breach
Talk to us
If you have a related question or are unsure how to keep your NEOM devices safe from cyber threats, you can talk to your line manager or contact CISO.
Question & Answer
Wrong. As part of our cybersecurity controls, we never use cloud-based data storage services to upload or share company-related information. Your manager would rather have you do the right thing – if you are struggling to send the materials through our email system due to their size, you should wait for CISO support on Sunday rather than sending the attachments out of compliance with our procedures.

Further Information
More information available in our:
However, you can also contact CISO with any concerns or queries regarding our approach to cybersecurity, or the IT Department for other IT-related concerns or queries.
Data Privacy
Why it matters
As pioneers of the world’s most advanced ‘cognitive city,’ NEOM will be entrusted with a large amount of personal data. We therefore have a duty to act as responsible stewards of this data, maintaining trust and transparency with those whose data we handle.
At NEOM, we believe in data-sharing for good and this means using data to produce outcomes that benefit humanity and make the world a better place. We also need to remember that ‘Respect’ is one of our Values, and we should ensure that this Value is upheld when we receive and process the personal data of others.
By ‘personal data,’ we mean any information that relates to a living person and that, when put together, could be used to identify them or make their identity available.
Our commitments
As a company, we are committed to:
- Maintaining the highest standards of data privacy, ensuring all personal data is collated and processed in compliance with applicable data privacy laws and regulations
- Holding personal data, according to defined retention periods, to satisfy the legitimate purposes for which it was collected
- Sharing personal data only where necessary and in line with all applicable laws and regulations
- Respecting the rights of individuals whose data we hold in line with applicable laws and regulations, such as the right to obtain copies of personal data and correct or erase the personal data we hold
- Using technology to increase transparency around the personal data processing we undertake, and empowering those whose data we handle by improving their ability to monitor and select how their data is used
- Training our colleagues on our data privacy standards so that they understand the company’s approach to respecting personal data (we can’t maintain our high standards without you)
- Ensuring that any third parties handling personal data on our behalf understand and apply our data privacy standards, for example by signing a data processing agreement
- Protecting the personal data of our partners as if it were our own
- Taking data privacy into account from the start, by ensuring that all new technologies we develop follow our high data privacy standards from day one
- Taking a risk-based approach to processing personal data, making sure that the highest-priority data is subject to any additional controls necessary to keep it secure
- Maintaining robust cybersecurity controls to protect the data we hold from any form of unauthorized access (see ‘Cybersecurity’ section)
Our expectations
As NEOM representatives, we expect you to:
Understand our data privacy commitments, ensuring you handle all relevant personal data responsibly and in compliance with all applicable data privacy laws and regulations
Treat the personal data of others with the same care and privacy as if it were your own
Inform your line manager or use our Speak Up channel if you encounter or suspect a personal data breach, or any behaviors that go against our data privacy commitments
Talk to us
If you have any queries about our data privacy standards, you can contact your line manager or the Data Privacy Office.
Further information
More information is available in our:
However, you can also contact the Data Privacy Office with any queries related to our data privacy commitments.