In my opinion, yes... But it doesn't have a lot of that content... And I think it's more of "cheating" than netorare. Since the beginning, it builds up the relationship between the two MC's and we can see the POV of the two of them as the time passes... At one moment we can choose to put them into a relationship... And then, as we control the woman, we can choose to do naughty things with the best friend of the MC (now our boyfriend) and also with other men in the game... Cheating on our BF this way. I am really not sure if the MC sees something of this or knows about it
Other thing that happens is that, when controlling the MC, there will be a woman that is interested in us, but if we take wrong decisions we will see how she fucks out best friend instead, I kind of felt that as NTR when I saw it and was hot, but I really prefer what happens between the MC and the FMC... That they become a couple and the FMC can cheat on him with some guys