GIFTS & HOSPITALITY

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.

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

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.

 MORE INFORMATION IS AVAILABLE IN OUR:

• Gifts and Hospitality Policy
• Anti-Financial Crime Policy
• Anti-Bribery and Corruption Manual
• Conflict of Interest Policy

However, you can also contact the Compliance Department with any questions regarding our approach to gifts and hospitality.