ANTI-BRIBERY & ANTI-CORRUPTION

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.

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.

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 ensuring 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

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

MORE INFORMATION AVAILABLE IN OUR:

• Legal Policy
• Acceptable Usage Standard
• Data Privacy Standards
• Safety Policy and Executive Safety Committee Charter

You can also contact the Compliance Department with any queries you may have about bribery and corruption.

MORE INFORMATION AVAILABLE IN OUR:

• Anti-Financial Crime Policy
• Anti-Bribery and Corruption Manual

However, you can also contact the Compliance Department with any queries or concerns you may have about bribery and corruption.