Ethics – the second commitment from the VINCI Manifesto – are central to all professional relationships between VINCI and its stakeholders. This commitment, led at the highest level, is integrated across all the Group’s business lines using a cross-business approach. VINCI has embraced a global acculturation approach engaging everyone to adopt collective and individual behaviours that are aligned with this commitment.
Two reference guides constitute the framework for the Group’s recommendations and requirements in this area:
These two documents are available in 31 languages on the Group’s website and intranet, and are included in the welcome pack for new employees. VINCI’s managers are formally committed to respecting them and ensuring that they are applied.
Working closely with all the Group’s functions, the Ethics and Vigilance Department supports the implementation of the Group’s compliance arrangements and specifically its corruption prevention procedures.
The Ethics and Vigilance Committee has seven members, five of whom also serve on the Executive Committee. It ensures that the compliance procedures covered by the Code of Ethics and Conduct are implemented and amended as necessary, particularly with regard to:
It oversees changes to the Code of Ethics and Conduct and the Anti-corruption Code of Conduct, and met seven times in 2021 (including three extraordinary meetings).
The network of ethics correspondents, coordinators and officers, made up primarily of general counsels and compliance officers, monitors progress and oversees the implementation of relevant action plans in the business lines.
The Ethics and Compliance Club, which brings together the Group’s General Counsel and the legal heads of the Group’s business lines, the Internal Control Director and the Ethics and Vigilance Director, monitors emerging regulatory developments and shares best practices, particularly in terms of training tools or third-party assessment processes. This club helps prevent unethical business practices. It met five times in 2021.
In addition, the GDPR Representatives Club, which is made up of representatives appointed by each of the Group’s business lines, provides support for the deployment and development of effective personal data protection processes, notably in accordance with Regulation (EU) 2016/679, known as the General Data Protection Regulation (GDPR). Coordinated by the Ethics and Vigilance Department, this club supports the sharing of tools and best practices, liaising closely with the Chief Information Security Officer (CISO). The GDPR Representatives Club, which met five times in 2021 (including one extraordinary meeting), is supported by a network of correspondents in the business lines.
VINCI has decided to deploy extensive resources with a view to continuously improving its anti-corruption measures and reinforcing its prevention of these risks.
Training and information are key factors for implementing the Group’s business ethics policy. To enable all employees to effectively contribute to preventing and detecting corruption, depending on their duties and responsibilities, training programmes are developed and rolled out at each of the Group’s organisational levels. These programmes ensure that employees understand the related domestic and even international legal regimes, and are fully aware of the issues involved and what is expected of them. The corruption scenarios identified and the associated risks are clearly presented, along with the procedures to be carried out to limit these risks, the best ways to respond to inappropriate demands, the procedures for reporting suspicions concerning corrupt conduct, as well as the disciplinary actions that may be taken or the criminal penalties that may apply to individuals for any infringement of rules or regulations. As exemplary managerial behaviour is essential to effectively spearhead ethical practices within its subsidiaries, the Group’s conduct guidelines are covered in all of the management training programmes provided by the academies.
27,467
staff trained on ethics in 2021
The Ethics and Vigilance Department regularly gives presentations for manager events (conferences) and cross-business network meetings, such as human resources, communications, tax expert, purchasing, insurance or finance seminars, as well as the Pivot Clubs.
