NEOM is not built by Saudi Arabia. It is built by a global supply chain of corporations — strategy consultants who designed the plans, architecture firms who drew the renderings, construction companies who poured the concrete, logistics firms who moved the materials, and technology partners who provided the systems. Each of these corporations operates under the legal frameworks of its home jurisdiction. Each has human rights obligations under the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights, and — for European firms — the emerging requirements of the EU Corporate Sustainability Due Diligence Directive. Each has a communications department that issues statements about corporate responsibility, sustainability, and ethical business practices.
None of these frameworks, obligations, or statements have prevented any corporation from profiting from a project where five men have been sentenced to death for social media posts, 21,000 workers have died, the kafala system traps workers in conditions the ILO is investigating as forced labour, and the project’s own CEO was recorded saying he drove his staff “like a slave.”
What follows is the record — as complete as available evidence allows — of every major category of corporate involvement in NEOM, what each entity has been paid where known, what human rights due diligence they have conducted where known, and what legal obligations they are failing to meet.
The Strategy Consultants
McKinsey and Company is NEOM’s principal strategy consultant. According to reporting by DeSmog in October 2024, McKinsey earns more than $130 million per year from its NEOM engagement. Over the nine-year period since NEOM’s inception, cumulative fees likely exceed $1 billion.
McKinsey designed the original scope of the project: the 170-kilometre linear city, the mountain ski resort in a desert where summer temperatures exceed 30 degrees Celsius, the floating industrial platform, and the broader NEOM concept. McKinsey then assisted with the preparation of the internal audit, reported by the Wall Street Journal in March 2025, that found the project would cost $8.8 trillion and take until 2080 to complete. The audit also found “evidence of deliberate manipulation” by management, who relied on “unrealistically rosy assumptions” to justify cost overruns — assumptions that executives, aided by McKinsey, had used to inflate projections.
McKinsey’s dual role — designing the strategy and auditing the strategy it designed — presents a conflict of interest so fundamental that it would not survive scrutiny in any regulated financial advisory context. The firm’s fees scale with the ambition of the plan: a $500 billion project requires more consulting than a $50 billion project. The incentive to validate ambitious plans, rather than challenge them, is embedded in the fee structure.
McKinsey’s spokesman stated that the firm “abides by international business rules” and is not involved in “manipulation of financial reporting.” The statement addresses the financial reporting question but does not address the human rights question: whether McKinsey conducted any assessment of the labour conditions under which the projects it designed would be built, and whether the $130 million annual fee includes any obligation to evaluate the human cost of the strategy it provides.
McKinsey’s Saudi practice extends beyond NEOM. The firm has been a principal advisor to the Saudi government across the Vision 2030 programme, a relationship examined in detail in MBS and the Consultants. Its role in shaping the Kingdom’s economic transformation — and the labour conditions under which that transformation is being executed — positions it as the most consequential foreign advisory firm in Saudi Arabia’s modern history.
Boston Consulting Group was involved in designing the Vision 2030 economic blueprint. Leaked consulting documents revealed that BCG had suggested partnering with NASA to create an artificial moon — “the biggest in the world.” BCG’s consulting heads were summoned before the US Congress in 2024 to disclose details of their Saudi engagements. Specific fee amounts have not been publicly disclosed.
Oliver Wyman and Strategy& (PwC’s strategy arm) have also provided advisory services to Vision 2030 programmes. The scope and value of their engagements have not been publicly documented with the same specificity as McKinsey’s.
The Construction Contractors
The construction tier represents the corporations most directly connected to the labour conditions documented by human rights organisations, because their employees — and their subcontractors’ employees — are the workers whose deaths, wages, and working conditions constitute the human cost.
Webuild (Italy’s largest engineering group) held a $4.7 billion contract for three dams and a 2.8-kilometre freshwater lake at Trojena. The contract was terminated effective 29 March 2026 at approximately 30 per cent completion. Webuild stated it would be “unharmed” by the termination, with NEOM reimbursing all costs including demobilisation. Webuild’s Italian operations are subject to Italian law and EU regulations, including the Corporate Sustainability Due Diligence Directive when it takes full effect.
Hyundai Engineering and Construction (South Korea) held a tunnel construction contract awarded in June 2022 as part of a consortium with Samsung C&T and Archirodon. The $1 billion contract for a 12.5-kilometre tunnel beneath The Line was terminated on 12 March 2026. Hyundai’s share was approximately $500 million.
Samsung C&T (South Korea) participated in the tunnel consortium and separately employed workers on NEOM tunnelling projects. FairSquare documented the death of Badri Bhujel, a 39-year-old Nepali machine operator employed by Samsung C&T, who died on 11 April 2024 of respiratory conditions linked to tunnel work. Samsung C&T has not publicly commented on worker deaths at its NEOM operations.
Bechtel, Fluor, and AECOM (United States) collectively won or were in final-stage negotiations for an estimated $4-6 billion in NEOM construction packages. Several packages have been suspended, reduced, or rebid at lower values. All three firms are subject to US law and the reporting requirements of US-listed corporations. None has published specific human rights due diligence assessments related to their NEOM operations.
Saudi Binladin Group (Saudi Arabia), one of the Kingdom’s largest construction firms and historically connected to the Saudi royal family, has been involved in NEOM construction. The firm’s Saudi incorporation places it outside the jurisdiction of international human rights legislation applicable to Western corporations.
Eversendai Corporation (Malaysia) held a structural steel contract for Trojena’s Ski Village in collaboration with Saudi Arabia’s Al Bawani Company. The contract was terminated on 26 March 2026, with the company citing the “escalating Middle East conflict” as the reason and preparing claims for compensation.
China Communications Services (China Comservice) — a Chinese state-owned enterprise — held construction contracts at NEOM including the healthcare facility where Abdul Wali Skandar Khan, 25, died on 28 December 2023. His death was the first formally documented worker fatality on a NEOM site. China Comservice did not respond to ALQST’s requests for comment.
The Architecture Firms
The architecture firms are documented in detail in the companion article “The Architects Who Stayed.” The summary for the complicity index:
Firms that withdrew: Norman Foster (advisory board, 2018), Coop Himmelb(l)au (human rights concerns), Morphosis (July 2024), Mecanoo, HOK, Adjaye Associates (removed by NEOM, August 2024).
Firms that remained: BIG (Oxagon), Zaha Hadid Architects (Trojena tower), OMA (Gulf of Aqaba resorts), Delugan Meissl Associated Architects (The Line lead designer, replacing Morphosis), UNStudio (Trojena), Gensler (The Line Phase 1), Studio Fuksas, Tom Wiscombe Architecture, Oyler Wu Collaborative, Peter Cook / Cook Haffner Architecture Platform.
Architecture fees on NEOM are not publicly disclosed. On a $50 billion construction programme, design fees typically range from 5 to 15 per cent of construction value — implying total architecture fees of $2.5 billion to $7.5 billion across all firms.
The Logistics Partners
DSV (Denmark), one of the world’s largest logistics groups, holds a 49 per cent stake in a $10 billion joint venture with NEOM for exclusive logistics and transport services until 2055. DSV’s total shareholder funding commitment through 2031 was $5 billion, of which DSV committed up to $2.45 billion. As of February 2026, the joint venture was “not operational, and no capital has been allocated to it.” DSV capped spending at $100 million in 2025 as project timelines slipped.
DSV is a Danish-listed company subject to Danish law and EU regulations. Its participation in a joint venture with an entity whose construction operations have been documented as involving forced labour conditions creates potential legal exposure under the EU Corporate Sustainability Due Diligence Directive. The joint venture agreement presumably includes provisions for labour standards compliance. Whether those provisions are enforced, and whether DSV has conducted independent verification of labour conditions in the NEOM zone, has not been publicly disclosed.
The Technology Partners
DataVolt (Saudi Arabia/US) announced a $5 billion partnership with NEOM in February 2026 for an AI data centre campus at Oxagon. The facility, a 1.5 GW installation, is designed for net-zero operations using Red Sea seawater for cooling.
Hexagon (Sweden/US) secured a $2.7 billion contract for smart-city data infrastructure at NEOM. Hexagon’s Swedish incorporation places it within the scope of EU due diligence requirements.
The technology partnerships represent NEOM’s strategic pivot from construction megaprojects to digital infrastructure. They also represent the expansion of the corporate ecosystem profiting from NEOM — and the extension of due diligence obligations to technology firms whose involvement is more recent and whose human rights assessments, if conducted, have not been published.
The Labour Supply Chain
The corporations listed above are the visible tier of NEOM’s supply chain — the firms whose names appear on contracts, press releases, and stock exchange filings. Below them operates a labour supply chain that is, by design, less visible and less accountable.
SMASCO (Saudi Manpower Supply Company) is one of the Kingdom’s largest labour supply firms. HRW’s investigation documented SMASCO workers who described being “kept like prisoners” — unable to leave company premises, unable to obtain regular work despite holding employment contracts, and unable to access the labour rights mechanisms that Saudi law nominally provides.
Recruitment agencies across Bangladesh, Nepal, India, Pakistan, and the Philippines form the first link in the supply chain. These agencies charge the recruitment fees — averaging $3,715 for Bangladeshis — that create the debt bondage documented by HRW and BWI. The agencies operate in the workers’ home countries, beyond Saudi regulatory authority, and are generally unregulated or lightly regulated by the sending country’s labour ministry.
The subcontracting structure at NEOM typically involves three to four layers: NEOM awards a package to a primary contractor; the primary contractor subcontracts elements to secondary firms; the secondary firms hire through labour supply companies; the labour supply companies recruit through agencies in South Asia. Each layer adds distance between the entity that commissions the work and the entity that employs the worker. The distance is not incidental. It is the mechanism that distributes — and thereby dissipates — accountability.
The Legal Framework
Three international frameworks create obligations for the corporations involved in NEOM. None has been effectively enforced.
The UN Guiding Principles on Business and Human Rights (2011) establish that corporations have a responsibility to respect human rights — including the obligation to conduct human rights due diligence, to avoid causing or contributing to adverse human rights impacts, and to seek to prevent or mitigate impacts directly linked to their operations, products, or services. The UNGPs are not legally binding. They are the international standard against which corporate conduct is assessed, and they form the basis for the emerging legislative requirements described below.
The OECD Guidelines for Multinational Enterprises (revised 2023) require enterprises operating in or from OECD member states to respect human rights, conduct due diligence, and avoid contributing to adverse impacts through their business relationships. The Guidelines include a complaint mechanism — the OECD National Contact Points — through which affected parties can file complaints against specific companies. No complaints related to NEOM have been publicly reported through this mechanism, though the process is not comprehensive in its disclosure requirements.
The EU Corporate Sustainability Due Diligence Directive (adopted 2024, with phased implementation) requires large EU-based companies and companies with significant EU turnover to identify, prevent, mitigate, and account for adverse human rights and environmental impacts in their operations and value chains. The Directive is directly applicable to European firms involved in NEOM — including Webuild, DSV, Hexagon, and the European architecture firms — and creates civil liability for failures to conduct adequate due diligence.
The Directive’s implementation timeline means that its enforcement mechanisms were not fully operational during the period of NEOM’s most intensive construction. As the 2034 World Cup construction ramp begins, the Directive will be in effect, creating a legal environment in which European corporations’ involvement in projects documented as involving forced labour carries potential civil liability in European courts.
ALQST’s Appeal
In November 2024, ALQST published a briefing paper that included a direct appeal to businesses involved in NEOM. The appeal called on corporations to:
Conduct independent human rights due diligence on their NEOM operations, including direct consultation with workers and communities affected by the project.
Use their leverage to advocate for the release of Howeitat tribe members imprisoned for opposing the displacement.
Publicly disclose their human rights policies as applied to their Saudi operations, including any assessments conducted and any findings identified.
No corporation publicly responded to ALQST’s appeal. The Business and Human Rights Resource Centre separately contacted a dozen firms about their human rights due diligence for NEOM involvement. Only three out of twelve companies responded — Keller Group Plc, McKinsey and Company, and Air Products — each providing a one-page generic statement with no engagement with specific issues such as displaced communities or forced evictions. The silence across the entire corporate ecosystem is not the silence of entities unaware of the questions. It is the silence of entities that have calculated the commercial value of their NEOM relationships against the reputational cost of answering them and concluded that non-response serves their interests better than disclosure.
The NEOM Code of Conduct
NEOM has published a supplier code of conduct that includes provisions for labour standards, safety, and ethical business practices. The code requires contractors to comply with Saudi labour law, provide safe working conditions, and respect workers’ rights.
The code’s existence creates a documentary defence: NEOM can point to its code as evidence that it has established standards for its supply chain. The code’s enforcement is a different matter. The conditions documented by HRW, ALQST, FairSquare, and BWI — wage theft, passport confiscation, death classification fraud, forced labour conditions — describe a supply chain that operates in systematic violation of the code’s provisions. The gap between the code and the practice is not a failure of drafting. It is a failure of enforcement — or, more precisely, a system in which the code serves a public relations function while the operations serve a construction function, and the two functions do not intersect.
The Accountability Arithmetic
The corporations involved in NEOM have earned, collectively, billions of dollars from a project characterised by:
Five death sentences for social media posts. Fifty-year prison terms for opposing eviction. Twenty-three years for a mother who posted condolences on Twitter. Twenty-one thousand worker deaths. One hundred thousand missing workers. Eighty per cent of deaths classified as “natural causes” without autopsy. Sixty-nine per cent of workers experiencing payment delays. Eighty-five per cent experiencing debt bondage. Sixty-five per cent experiencing passport confiscation. An ILO forced labour complaint upheld for admissibility.
Zero corporations have published independent human rights due diligence assessments of their NEOM operations. Zero have publicly called for the release of imprisoned Howeitat tribe members. Zero have conditioned their continued involvement on specific labour reforms. Zero have responded to ALQST’s appeal.
The complicity is not individual. It is structural. It operates through the same mechanism that distributes liability down the subcontracting chain: each corporation can point to another as the responsible party. McKinsey advises; it does not build. BIG designs; it does not pour concrete. Webuild contracts; it does not recruit workers. DSV transports; it does not employ labourers. NEOM commissions; it is not the kafala. The kafala is the law; it is not any single corporation.
The chain of deniability is the chain of complicity. Each link in the chain enables the next. The strategy that McKinsey designed required the construction that Webuild contracted. The construction required the labour that the kafala trapped. The labour required the recruitment fees that created the bondage. The bondage required the isolation that prevented complaint. The prevention of complaint required the classification system that erased the deaths. And the erasure of the deaths required the silence of every corporation in the chain — a silence that, as of April 2026, remains unbroken.
This investigation draws on DeSmog (McKinsey fee reporting, October 2024); TechCrunch (McKinsey and internal audit, March 2025); contractor filings from Webuild, Hyundai E&C, Samsung C&T, Eversendai, and DSV; ALQST (November 2024 briefing paper and business appeal); Human Rights Watch (“Die First, and I’ll Pay You Later,” December 2024); Building and Wood Workers’ International (ILO complaint, June 2024); FairSquare (“Underlying Causes,” May 2025); the Business and Human Rights Resource Centre; Dezeen (architecture firm investigation, June 2024); the UN Guiding Principles on Business and Human Rights; the OECD Guidelines for Multinational Enterprises; the EU Corporate Sustainability Due Diligence Directive; and NEOM’s supplier code of conduct. Vision2030.AI is editorially independent and is not affiliated with NEOM, PIF, or any official Vision 2030 entity.