No, that's incorrect. Anything without a moral stance is Neutral. Animals, Elementals, and people who just want to live their daily lives. To be Neutral Evil is to be more than just merely apathetic towards Good and Evil, Law and Chaos, it's pulling others down to raise yourself up. And generally Neutral people don't always take the neutral approach, they perform good and evil acts - help a guy out here, be a selfish prick there.