Governance

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NEO is compliant with all applicable anti-corruption legislation. We are committed to acting fairly and ethically and to preserving the trust and confidence of business partners, and anyone else affected by our operations. Our Anti-corruption Policy sets out the ethical principles to which we strictly adhere to on a global basis in relation to bribery and corruption and reporting.

We also adhere to several policies to ensure ethical and transparent reporting, based on leading international standards for responsible business conduct, including the UN Global Compact and the UN Guiding Principles on Business and Human Rights. Our goal is to make ethical, responsible and profitable decisions when conducting business.

Transparency on the economic impacts of a company’s activities is crucial. NEO annually reports its financial impact through its annual report, ensuring transparency between the company, our owners, regulators, and the rest of society.

In 2022, NEO met the threshold for corporate governance reporting requirements for UK companies under the Companies (Miscellaneous Reporting) Regulations 2018. NEO now applies the Wates Corporate Governance Principles for Large Companies (“Wates Principles”), which was voluntarily adopted in 2022. During the year ended 31 December 2022, the Group’s internal processes were applied on a basis considered generally consistent with the Wates Principles.

We also adhere to several policies to ensure ethical and transparent reporting, based on leading international standards for responsible business conduct, including the UN Global Compact and the UN Guiding Principles on Business and Human Rights. Our goal is to make ethical, responsible and profitable decisions when conducting business.

Transparency on the economic impacts of a company’s activities is crucial. NEO annually reports its financial impact through its annual report, ensuring transparency between the company, our owners, regulators, and the rest of society.

In 2022, NEO met the threshold for corporate governance reporting requirements for UK companies under the Companies (Miscellaneous Reporting) Regulations 2018. NEO now applies the Wates Corporate Governance Principles for Large Companies (“Wates Principles”), which was voluntarily adopted in 2022. During the year ended 31 December 2022, the Group’s internal processes were applied on a basis considered generally consistent with the Wates Principles.

The UN SDGs and net zero targets cannot be achieved in isolation, and we recognise there is a shift in how businesses need to operate, increasing partnerships, interconnectivity and coordinating efforts across regulators, operators, supply chain, industry bodies, skill sets and technology centres. There are opportunities for us to build on and develop partnerships within our value chains or through sectoral initiatives that bring together leaders to establish or raise industry standards. In this regard, we actively engage in dialogue with companies, governments, and the supply chain looking to strengthen coordination between initiatives. As a largely non-operator, we are committed to maintaining an open, honest relationship with the joint-venture partners ensuring successful collaboration.

We work closely with regulators and government departments, including the NSTA, BEIS, HSE, OSDR and OPRED and ensure we are fully aligned with the regulatory and reporting environment. We participate in relevant consultations guiding sector policies, sharing our expertise. The company is an active member of many OEUK steering committees and are always seeking to participate in other groups and fora where we can best support and meaningfully contribute.

Looking forward, we will continue to build on our ESG strategy through embedding a sustainable culture and widening engagement to encouraging employees to take a more proactive role to drive positive change. We will establish a NEO Sustainability Champions Group across the company to enable employees to channel initiatives and ideas related to ESG and sustainability. By engaging people across the organisation, we will allow the company to gain greater insight into how practical measures can be taken to make a material difference. We are also looking to extend our partnerships with low carbon technology centres.

Policies

NEO adheres to a number of policies to ensure ethical, transparent reporting. The policies are based on leading international standards for responsible business conduct, including the UN Global Compact and the UN Guiding Principles on Business and Human Rights.

Code of Conduct

NEO have ten core principles that describe our expectations regarding the Company’s business conduct, which are based on leading international standards for responsible business conduct, including the UN Global Compact and the UN Guiding Principles on Business and Human Rights. The Company’s goal is to make ethical, responsible and profitable decisions when conducting business.

The ten principles included in this Code of Conduct are:

• We comply with laws
• We respect our colleagues
• We ensure healthy and safe working conditions
• We protect our assets and confidential information
• We respect fundamental human rights
• We never make unlawful payments
• We choose our business partners carefully
• We avoid conflicts of interest
• We compete fairly
• We operate in an environmentally responsible manner

Anti-Corruption Policy

NEO complies with applicable anti-corruption legislation. We are committed to acting fairly and ethically and to preserving the trust and confidence of business partners, and anyone else affected by our operations. The Anti-corruption Policy sets out the ethical principles to which NEO strictly adheres to on a global basis in relation to bribery and corruption and reporting.

We have a zero-tolerance policy towards bribery and corruption by anyone involved in our business, regardless of rank or position. As part of HitecVision’s compliance program for their portfolio companies, “We behave and comply”, all NEO Energy staff and contractors are required to complete the UN’s anti-corruption e-learning programme – “Fighting Corruption”.

Gift and Hospitality Policy

A gift and hospitality procedure is in place and NEO’s Compliance Officer is responsible for implementing and monitoring this. Expenses for gifts and hospitality that exceed the limits for self-approval, must be reviewed by the Compliance Officer in each case. The Compliance Officer maintains a register of all gifts and hospitality expenses.

Whistleblowing Policy

The purpose of the Whistleblowing Policy is to provide employees with guidance as to how to raise any concerns and reassure staff that they can raise genuine concerns without fear of reprisals.

NEO’s management team encourage employees to report suspected wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be respected.

Modern Slavery Act 2015

NEO Energy has a zero-tolerance approach to modem slavery and are committed to ensuring that there is no modem slavery or human trafficking in any part of our business, including our supply chain.

NEO has a number of measures in place to reduce the risk of modern slavery affecting its business and supply chain including,

• Reviewing the supply chain
• Ensuring contractual terms are to the highest standard of ethical business
• Ensuring visibility of the Whistleblowing Policy

Aligning with International Frameworks

NEO recognises the need for transparency to ensure the trust of all stakeholders and continues to report against the following frameworks.

The Sustainable Development Goals are a call for action by all countries – poor, rich and middle-income – to promote prosperity while protecting the planet.