2021 UNIVERSAL REGISTRATION DOCUMENT

General and financial elements

4.3.3 Preventing serious human rights infringements in the Group
  • Guidelines incorporated into internal processes and operating procedures

Business units and divisions gradually incorporate guidelines into their internal rules and procedures. For example, in internal procedures manuals for key processes, such as recruitment, VINCI Construction Grands Projets has included issues that should alert users to potential human rights risks. Along with other Group divisions, it has also reviewed and validated its internal standards for living conditions, which are based on the Group’s guidelines but adapted to the division’s business activities. In addition, VINCI Construction Grands Projets significantly expanded the human rights component of its tendering guide to help the teams preparing responses to calls for tenders to better understand and manage risks early in the process.

VINCI’s guidelines are also directly incorporated into processes and procedures at the company and project levels. Issues such as wage levels, working hours, paid holidays, workers’ representation, discrimination, and hiring underage workers are first assessed and managed according to the human resources procedures and rules applied by companies and projects. Rules on site safety, managing the various levels of subcontracting at sites under their control, promoting dialogue and managing negative impacts on local communities are also applied locally. In this context, the Group provides a key means of support by facilitating audits of human rights risk management in subsidiaries and projects. Such audits are opportunities to perform joint assessments, take into account the operating environment and identify any areas for improvement (see paragraph 4.3.4, “Assessing the situation of subsidiaries, subcontractors and suppliers”, page 245).

  • Addressing and prioritising issues at the country level

An understanding of the local context is essential to determining which issues are most relevant and conducting appropriate preventive actions. For this reason, VINCI also maps risks for individual countries, enabling the various issues and themes to be more accurately analysed for a given context and prioritised accordingly. These country risk maps are informed by reports published by public administrations, international organisations, non-governmental organisations, academics, trade unions, the media, and so on, and include insight into the country’s legal and institutional frameworks. As a result, they provide a more granular picture of the risks inherent to each country and business sector and are a foundational resource for assessing a subsidiary’s situation. They are also essential tools for making the Group’s employees and partners aware of the risks in their operations, contractual arrangements and partnerships that require special scrutiny. Country risk maps are updated to reflect dialogue with employees and feedback from teams on the ground.

Country-specific analysis of human rights risks

  • 24 country-specific human rights risk maps, developed with the support of an external provider, available in 2021
  • 17 human rights country fact sheets produced by the CSR Department, which also helps in preparing responses to calls for tenders
  • Specific risk analysis covers 27% of the Group’s international workforce (excluding France) (*) and 91% of the workforce in countries identified by the Group as high-priority (*) with respect to these human rights risk assessments

(*) The 2021 action plan is based on data at 31 December 2020.

  • Awareness and training initiatives for employees and managers

VINCI considers that in matters of human rights, leaders play a decisive role. The Group places emphasis on awareness and training initiatives for managers and employees. It aims to foster a culture of human rights risk prevention, as it has done in the area of safety, and provide tools to help operational teams take preventive action as early as possible.

In 2019, after a year of collaborative in-house development, VINCI launched an e-learning course to raise awareness of human rights risks. It is currently available in five languages: English, French, Polish, Portuguese and Spanish. Although open to all entities and employees, the course primarily addresses managers and those in charge of human resources, administration, finance, and health and safety. Completion is monitored and reported to the Human Rights Steering Committee. At the end of 2021, more than 4,000 employees in the target groups, in nearly 70 different countries, had finished the course. A complementary course for managers of concessions was developed in 2021. It delivers an interactive presentation of the issues that may arise during a project’s three phases: development, design-construction and operating-maintenance. In addition, several of the Group’s well-established, emblematic training programmes now include a human rights component. One example is Team Grands Projets, a training course implemented across the construction and energy businesses to build the skills of managers of major projects and help them handle complex environments more effectively.

  • Alert mechanisms for raising concerns

The Group also upholds its commitments by providing multiple channels by which employees can report concerns. Grievance procedures include contacting human resources departments, health and safety representatives, line managers or employee representative bodies. If confidentiality is a concern, employees can also approach the ethics officers of the Group’s business lines and divisions or at Group level.