Code of Conduct & Business Ethics Policy

Effective Date: 01 June 2015 |  Last Review Date: 01 April 2025  | Owner: Management |  Version: 1.2

At Neutrino Group and its entities, integrity is not just a policy – it is the foundation of how we operate. This Code of Conduct sets the ethical standard we hold ourselves to in every client engagement, partnership, and internal decision.

1.  Our Values

Neutrino Group and its entities are guided by the following core values in everything we do:

  • Integrity — We act honestly, transparently, and do what we say
  • Respect — We treat every person with dignity and fairness
  • Excellence — We deliver quality in all our work
  • Accountability — We take responsibility for our actions and decisions
  • Innovation — We embrace technology and new ideas
2.  Scope

This Code applies to all Neutrino Group and its entities employees, directors, contractors, and anyone acting on the company’s behalf. Compliance with this Code is a condition of engagement with Neutrino Group and its entities.

3.  Honest & Fair Dealing

We expect all personnel to:

  • Be honest in all business communications and dealings
  • Compete fairly and in accordance with applicable laws
  • Never misrepresent Neutrino AI, its services, or its capabilities
  • Honour all contractual commitments to clients, partners, and suppliers
4.  Conflict of Interest

A conflict of interest arises when personal interests could interfere — or appear to interfere — with business decisions. All personnel must:

  • Disclose any actual or potential conflict of interest to management
  • Avoid making business decisions driven by personal gain
  • Obtain approval before pursuing outside business activities that could conflict with the interests of Neutrino Group and its entities.
5.  Confidentiality & Data Protection

All employees and contractors must:

  • Protect confidential information of Neutrino Group & its entities, clients, and
  • Not share or use such information outside of its intended purpose
  • Comply with applicable data protection laws, including UAE Federal Law No. 45 of 2021 on Personal Data Protection
6.  Compliance with Laws

Neutrino Group and its entities operates in full compliance with UAE law and all applicable international regulations, including those governing anti-bribery, tax, data privacy, export controls, and trade sanctions. All personnel are expected to be aware of and follow the laws relevant to their roles.

7.  Respect in the Workplace

Neutrino Group and its entities are committed to a workplace free from discrimination, harassment, and bullying. We value diversity and do not tolerate any form of unfair treatment based on gender, nationality, religion, age, or any other protected characteristic.

8.  Use of Company Resources

Company resources — including technology, data, time, and funds — must be used responsibly and only for legitimate business purposes. Misuse or misappropriation of resources is a serious violation of this Code.

9.  Social media & Public Communication

When engaging on social media or in public forums, all personnel must:

  • Not represent personal views without authorization
  • Maintain professionalism and respect for clients, partners, and colleagues
  • Protect confidential and commercially sensitive information
10.  Reporting Violations

Anyone who becomes aware of a breach or potential breach of this Code is encouraged to report it promptly to management. Neutrino Group and its entities takes all reports seriously and commits to investigating them fairly and without retaliation against good-faith reporters.

8. Consequences

Breaches of this Code may result in disciplinary action, up to and including termination of employment or contract. Serious breaches may also be referred to the appropriate legal authorities.