CONFLICTS OF INTEREST

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.

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

AS NEOM REPRESENTATIVES, WE EXPECT YOU TO:

• 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

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.

MORE INFORMATION AVAILABLE IN OUR:

• Conflict of Interest Policy
• Anti-Bribery and Corruption Manual

However, you can also contact the Compliance Department with any queries you may have about conflicts of interest.