CODE OF CONDUCT

HYPOTHETICAL SCENARIO: I work as a manager in our Procurement Department. Recently, one of my team members sent me an email. She said she was concerned that one of her colleagues had a personal interest in a potential supplier and that this might be affecting his decisions at work. I’m pretty sure that ‘conflicts of interest’ is a Compliance Department issue, and I wouldn’t know how to answer this concern properly. So, I think I’d better just thank her for the email and get back to work. Can’t do any better than that, right?

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.

HYPOTHETICAL SCENARIO: I work on one of our construction sites. We recently engaged a third-party construction company to provide a large number of additional laborers from abroad. We’re working against some tight deadlines here and could really use the extra help. Their workers have been on site for a few days now and the results are great – things are moving along so much faster than before! My only concern is that they seem to work constantly. I’ve never seen them take any breaks, not even during the hottest part of the day. They have their own supervisor, but he tells me that’s normal where they come from, and I shouldn’t worry about it. I figure he knows better and, at the end of the day, we’re talking about third parties here, not NEOM employees. So, I’ll put it out of my mind for now and look forward to finishing the project. I mean, it’s none of my business, right?

Wrong. We are committed to providing a healthy and safe environment for all those working on our sites. This includes third-party contractors. Where migrant workers are concerned, we need to pay particular attention to their working conditions, as they could be more vulnerable than others to mistreatment. If you feel that our commitments to a healthy and safe working environment are not being upheld by our partners, you need to let us know. You can do so by contacting your line manager, a member of the Compliance Department, or our Speak Up channel. If your job involves working alongside third parties regularly, you can also help us to ensure these partners share our human rights commitments, by communicating our standards regularly and helping them to improve.

HYPOTHETICAL SCENARIO: I work as a manager in our Marketing team. I’ve just been told that we’ll be taking on a new staff member very soon and I couldn’t be happier about it (things have been really busy around here!). The only issue is that my friend’s daughter is applying for the job. My friend keeps reminding me about it, as if I’m going to make sure she gets hired, but I would never do that. I’m a professional. Yesterday, my boss asked me to help out with the selection process. I know this will probably involve interviewing my friend’s daughter, but I have no intention of letting the relationship affect my decision-making, so I figure I’ll keep it to myself. I mean, it’s irrelevant, right?

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.

HYPOTHETICAL SCENARIO: My work takes me to some of our construction sites. Yesterday, I visited one of our sites to drop off an urgent piece of work which my colleague had been requesting. When I dropped it off, my colleague made a joke about my work taking so long to complete and needing extra effort to make it acceptable. This is not the first time he has done this. It’s starting to make me feel uncomfortable, but I’m not sure what to do. I don’t want to cause any trouble, but value my reputation for doing great work. I think I won’t say anything and hope he stops.

Wrong. Such conduct might very well amount to bullying and harassment. NEOM takes a zero tolerance approach to bullying and harassment of any kind. Even if you think your colleague is only joking, what’s important is how this behavior makes you feel. At NEOM, what we care about is the impact of behavior like this – not just the intent. If you feel subjected to such behavior, you should notify your manager, another senior colleague, or our Speak Up channel as soon as possible. As long as your report is made in good faith, we will protect you from any form of retaliation.

HYPOTEHTICAL SCENARIO: I’ve been working late a lot recently on a new project with some third-party contractors. It’s Thursday night and I’m finally about to leave for the weekend. All I need to do is send some project information to our external partners, so that they can review it first thing on Sunday morning – but the attachments are too big! My colleagues have already left and I’m eager to leave as well, but I can’t figure out how to make my attachments any smaller. Then I remember that my personal cloud storage account allows me to upload files and share them through a link, without the need for any attachments. Great! I’ll send the files that way, then get out of here. It’s the best thing I can do in the circumstances, right?

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.

HYPOTHETICAL SCENARIO: I work as a member of our Procurement team. I’m pretty new but everyone around here seems really nice – including our suppliers! I’ve been getting to know some of them quite well over the last few weeks, as we’ve been working on a big new tender, and they all have lots of questions to make sure they get their proposals just right. One of my regular contacts even sent me something for my birthday. Don’t worry, it wasn’t money. It wasn’t even really a gift. They just sent me some online vouchers I can use next time I need to get some new clothes. I’d never let this kind of thing influence my decision-making (I’m better than that) – but I could really use a new pair of jeans. So, I think I’ll use the vouchers, then let them know it was a really nice gesture, but it’s not going to affect the outcome of the tender. It’s the most responsible thing to do, right?’

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.