Our Respect for Governance

Ethical Business Practices

Neo’s Policy Commitments for responsible business conduct are embedded throughout all its commercial activities, operations, and relationships. When policies are in breach, there is either a process or someone responsible for remediation of negative impacts. Within the documentation of the corporate policies, there is also an indicated mechanism for employees to seek advice and raise concerns.

Responsible Procurement and Supply Chain Management

Neo adopted the OECD’s Model Policy for a Responsible Global Supply Chain of Minerals from Conflict- Affected and High-Risk Areas.

For this reason, it is in the process of conducting a holistic adoption and application of the following standards:

  • Supply Chain Policy Incorporated into Contracts
  • Tantalum Ore Sourcing Standard
  • Tin Sourcing Standard
  • Cobalt Sourcing Standard
  • Rare Earth Elements tracing compliance mechanisms: Strong Government Standards,Licensed Suppliers from the People’s Republic of China, Certifications (e.g. RMA Standard, RMAP, ISO-14001, SA-8000, EcoVadis Surveys), and Third Party Audits

Human Rights Protection and Promotion

In 2021, Neo’s team developed a distinct Human Rights Policy document, which the Board of Directors unanimously accepted.

Neo fully supports the United Nations Universal Declaration of Human Rights and is committed to respecting all International Labour Organization (ILO) core human rights standards. Neo also endorses the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises, the United Nation’s Guiding Principles on business and human rights and the ILO Declaration on Multinational Enterprises.

Neo does not employ children, in compliance with Convention 138 of the ILO. With the only exception being summer internships and vocational training programs organized in cooperation with schools or competent authorities, Neo will apply ILO C138 Framework for Minimum Age.

In accordance with ILO Conventions 29 and 105, Neo will under no circumstances make use of forced or bonded labour. Neo believes in a world of eradicated Modern Slavery.

In accordance with ILO Conventions 87, 98 135 and Recommendation 143, Neo recognizes and respects the freedom of its employees to choose if they want to participate in the establishment or association of an employee organization of their own choosing, such as a labour union and collective bargaining units, without Neo’s prior authorization.

In accordance with ILO Conventions 100 and 111, Neo is committed to an inclusive work culture and recognizes that all employees are to be respected for their individual abilities. Neo does not tolerate any form of harassment or discrimination on the basis of gender, religion, race, national or ethnic origin, cultural background, social group, disability, sexual orientation, marital status, age or political opinion.

Communication of Critical Concerns to Highest Governance Body

Neo’s Board of Directors – its highest governance body – receives regular information summarizing all critical concern reports and activity relating to it.

Neo’s Whistleblower Reporting and Non- Retaliation Policy: Neo’s policy addresses our corporation-wide commitment to integrity and ethical behaviour by helping to foster and maintain an environment where employees and others can report concerns about wrongdoing or suspected wrongdoing without fear of retaliation, discrimination or harassment. The purpose of this policy is to report Good Faith concerns regarding the business practices of Neo. All employees are responsible for reporting wrongdoings or suspected wrongdoings, using the procedures in Neo’s policy.

Reporting Mechanism for Employees:

Employees are strongly encouraged to discuss any concerns first with their supervisors, managers or other senior management. Supervisors and managers are required to notify their supervisors if they receive a report of wrongdoing or suspected wrongdoing.

Supervisors and managers will maintain confidentiality to the extent possible and treat the reporters with respect and escalate the reports in accordance with this policy and procedures. Alternatively, employees may contact the Chair of the Audit Committee, the Corporate Secretary, or Neo’s legal department. Alternatively, Neo has established procedures by which employees may make a confidential report through a third-party company, NAVEX Global®.

Reporting for Third Parties: Neo has also established procedures by which persons other than employees may communicate confidentially a critical concern to the highest governing body. Reports or claims of financial wrongdoing are delivered to the Chair of the Audit Committee and the Corporate Secretary. All other reports of non-financial wrongdoing are delivered to the Corporate Secretary and a designated member of the Neo’s legal department. Reports to the third-party company, NAVEX Global®, can also be made on an anonymous basis. Concerned parties can also submit an online confidential concern or call a toll-free phone line that is posted on the following secure website: www.neo.ethicspoint.com. The phone line is available 24 hours a day, seven days a week, 365 days a year.

Investigation of Critical Concerns:

Every financial report or non-financial report received will be promptly and thoroughly investigated under the direction of Neo’s highest governing body – its Board of Directors – or committee of the Board, and/or the Corporate Secretary and/or Neo’s legal department, depending on the nature of the report. The specific action taken in any particular case depends on the nature and gravity of the conduct or circumstances reported and the results of the investigation. Information disclosed during the course of the investigation will, to the extent practical and appropriate, remain confidential, except as may be reasonably necessary under the circumstances to facilitate the investigation, take remedial action, or comply with applicable law. Internal resources (e.g., members of the NEO human resources or legal departments) as well as external resources (e.g., external legal counsel, accounting or consulting services, etc.) may be utilized to assist in the investigation as deemed appropriate. Employees must cooperate fully with all investigations and comply promptly, completely and truthfully with all requests for information. No employee shall interfere in an investigation or alter or destroy documents or records related to an internal or external investigation.

Non-Retaliation: Neo strictly prohibits and does not tolerate retaliation against an employee or grievances for:

  • any financial report or non-financial report made in good faith;
  • providing information or causing information to be provided, directly or indirectly, in an investigation conducted by Neo or any federal, state or local regulatory agency or authority;
  • reports concerning the violation of any applicable law, rules or regulations, including those governing safety, health, discrimination and harassment; or
  • participating in an investigation, hearing, court proceeding or other administrative inquiry in connection with a report of wrongdoing.

    Neo’s policy encourages the reporting of wrongdoing or suspected wrongdoing by Neo’s employees and presumes that employees will act in good faith and will not make false accusations. Neo will not punish reporters for reports that cannot be substantiated, so long as the report was made in good faith.

Information Technology User Policy and Cyber-security

All employees with access to Neo’s IT network infrastructure are trained on cybersecurity annually. Every new Neo employee has to read and sign for compliance to the corporate Information Technology User Policy.

Anti-Workplace Harassment and Anti-Discrimination

Neo’s Anti-Workplace Harassment Policy: Every Neo employee has to abide by the antiworkplace harassment corporate guidance, as defined in the Anti-Workplace Harassment Policy document that is signed at commencement of employment. Neo is committed to maintaining a work environment free of harassment and has put in place this policy prohibiting harassment, which has been approved by the Board of Directors of the Company. There is zero-tolerance for harassment in the NEO workplace of any kind, by co-workers, supervisors, other employees, directors, customers and vendors. The Company defines harassment as the engagement in unwelcome conduct (verbal, physical or visual) that unfairly criticizes or shows hostility or aversion toward an individual because of their race, color, religion, sex (including same sex), national or ethnic origin, age, pregnancy/ marital status, disability, genetic information, or other characteristics protected by applicable laws

Neo’s Code of Business Conduct and Ethics Policy: Additionally, every Neo employee has to abide by the anti-discrimination corporate guidance, as defined in the Neo Code of Business Conduct and Ethics Policy document that is signed at commencement of employment. The comfort and diversity of our employees are tremendous assets. We provide equal opportunity in all aspects of employment and will not tolerate discrimination or harassment of any kind. Derogatory comments based on racial or ethnic characteristics, unwelcome sexual advances and similar behaviour are prohibited. Neo does not tolerate any form of discriminatory harassment – whether physical or mental in nature.

Anti-Corruption and Anti-Bribery

Neo is dedicated to the dynamic, ethical and profitable expansion of its operations worldwide. We compete for all business opportunities vigorously, fairly, ethically and legally and will pursue and negotiate contracts in a fair and open manner. Regardless of any pressures exerted, the Company will conduct business using only legal and ethical means. Neo’s operating facilities, subsidiaries, affiliates and joint ventures conduct every business transaction with integrity, regardless of differing local manners and traditions, and strive to comply with all regulations including, but not limited to:

  • the laws and regulations of Canada, particularly the Corruption of Foreign Public Officials Act (CFPOA);
  • the laws and regulations of the United States, particularly the Foreign Corrupt Practices Act (FCPA); the laws and regulations of the United Kingdom, particularly the U.K. Bribery Act (UKBA);
  • the laws and regulations of other countries in which Neo conducts business;
  • Neo’s Code of Business Conduct and Ethics;
  • Neo’s policies and procedures.

Record Keeping

Every Neo employee has to abide by the record keeping guidance, as defined in the Neo Code of Business Conduct and Ethics Policy document that is signed at commencement of employment and re-signed annually.

Preventing or Managing Conflicts of Interest

Every Neo employee has to abide by the conflict-ofinterest guidance, as defined in the Neo Code of Business Conduct and Ethics Policy that is signed at commencement of employment and re-signed annually.

Corporate vs. Personal Opportunities

Every Neo employee has to abide by the corporate opportunities guidance, as defined in the Neo Code of Business Conduct and Ethics Policy that is signed at commencement of employment. We do not personally take opportunities that are discovered through the use of Neo’s property, information or position without the prior consent of our Board. Our directors, officers and employees are also prohibited from competing with Neo.