Hello,
it is not exact, more accurate: energy deposition at a step is the sum of ionisation energy loss, which includes energy transfer for atoms below production threshold of secondary particles: delta-electrons, bremsstrahlung gamma, low energy nuclear recoil after elastic scattering. Non-ionizing energy loss is an estimation of energy loss due to multiple scattering.
In very low energy neutron is captured by a nucleus, then extra energy (about 8 MeV) is delivered by production of gamma or electrons.
VI