Our Respect for Governance

Stakeholder and Public Engagement

Approach to Stakeholder Engagement

Neo strives to be in meaningful engagement and transparent communication with its external stakeholders as frequently as possible.

Our external stakeholders include customers, shareholders, local communities, governments, suppliers, media, industry associations and civil society. For everyone one of our stakeholders, there is at least one employee at Neo responsible for the relationship management and communicating internally any concerns or opportunities as they arise. Our approach to stakeholder engagement includes virtual or inperson meetings, surveys, focus groups, community events attendance, written communication, industry consultation participations, and conference participation.

Our engagement with external stakeholders is guided by the Neo Code of Business Conduct and Ethics Policy document, which every employee has access to and has been trained on.

Ethical and Responsible Engagement with Government

Every Neo employee has to abide by the government relations corporate guidance, as defined in the Neo Code of Business Conduct and Ethics Policy document that is signed at commencement of employment.

In compliance with the Corruption of Foreign Public Officials Act (Canada), the United States Foreign Corrupt Practices Act and the Bribery Act (United Kingdom), we do not give anything of value, directly or indirectly, to officials of foreign governments or foreign political candidates in order to obtain or retain business. We do not promise, offer or deliver to any foreign or domestic government employee or official any gift, favour or other gratuity that would be illegal. A member of Neo’s legal department can provide guidance in this area.

 The laws or customs of other countries in which we operate may be less clear. It is our policy to comply with those laws or customs; however, if a local law or custom seems to contradict the principles described in the Code, contact a supervisor or a member of Neo’s legal department for guidance.

Active Corporate Citizenship in Public Policy Dialogues

Neo is actively engaged in lobbying in the European Union. Our advocacy activities concern the establishment of a resilient supply chain of rare earths and permanent magnets for European automotive, industrial pump and wind turbine manufacturing. Specifically, Neo participated in the industry consultations (“cluster meetings”) of the European Raw Materials Alliance (ERMA) and EIT Raw Materials – in effect informing Action Plan on Critical Raw Materials, the 2020 List of Critical Raw Materials, and the EU’s foresight study. Neo has not contributed either or in-kind political contributions to any public authority beneficiaries concerning directly Neo’s business activities.

Within the industry consultation framework of the European Raw Materials Alliance, Neo participated in EU advocacy activities in 2021 and 22. Neo’s advocacy was centered around informing the European Commission, the European Parliament and the Government of Estonia of amendments to funding mechanisms of the EU, in order to unlock the business case of large-scale development of rare earth magnet manufacturing in Europe. By extension, this would support the EU’s vision to develop domestic supply chains of critical raw material. Neo’s advocacy activities in the EU are reported in the EU Transparency Registry.

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.