Although the Group has a system in place (see paragraph 4.5, “The Group’s system for whistleblowing, alerts and the processing of reports”, page 258), in light of VINCI’s multi-local organisation and the nature of its activities, the implementation of local grievance channels is also encouraged. The Group’s view is that grievance procedures, including those initiated by end users or local residents, are more effective when they are local, since the company, project or worksite is then better positioned to proactively handle reports, identify any weak areas, improve processes and reinforce prevention. A number of Group companies have set up alert mechanisms in addition to hierarchical channels to report behaviours or situations that present a risk, such as a human rights risk. The alternative alert mechanisms include a dedicated email address, hotline or digital solution. Some companies, such as LISEA in France and Lima Expresa in Peru, have a contact point for the public on their websites. Others outsource the processing of reports to an independent body. This is the case for Seymour Whyte in Australia as well as Lima Expresa.
Although VINCI entities are sometimes the customers, they are also very often in the role of the subcontractor or service provider for customers in the public or private sectors. In these situations, Group entities are encouraged to participate in the processes put in place by their customers.
The Group has developed a tool to assess practices, based on its five salient issues and 17 themes. It consists of a series of precise questions on each theme to evaluate whether the management systems in place conform to the Group’s guidelines and whether they specifically address and prevent the risks identified in a given country, in the subsidiary’s own operations and in its relations with subcontractors and temporary employment agencies. Based on the results, the entity or project builds an action plan and reports on it to its division’s Human Resources Department, which in turn informs the Group through its steering committee representative. As necessary, major risks are monitored and assessed at Group level. These assessments are generally conducted by the CSR Department and by specifically trained staff in business lines and divisions. They may entail additional interviews with employees of the subsidiary, subcontractors or service providers working on the site.
In 2020, the assessment tool was updated to reflect user experience and critical feedback from several corporate and human rights experts, and in 2021 the CSR Department developed a digital platform to make it available to all Group employees.
VINCI’s Internal Audit department has begun updating the risk scorecards used by risk committees to assess projects. Consideration of non-financial risks, in addition to technical and financial risks, has been reinforced. Human rights risks include risks relating to recruitment practices, accommodation and impacts on local communities and nearby residents. Prior to new acquisitions, a human rights risk assessment must be conducted and examine such aspects as the country of operation, the company’s commitments and the resources devoted to preventing human rights risks.
In VINCI’s businesses, whether in construction, energy or concessions activities, the major challenges are at the operational level. Accordingly, when it comes to vigilance with regard to human rights risks in the value chain, priority is given to subcontractors and temporary workers employed at worksites and sites under operation.
The Group has provided all entities with a due diligence methodology that includes the following steps: mapping human rights risks for subcontractors and service providers, applying specific criteria during the selection phase, including specific clauses in contracts and monitoring compliance with contractual obligations. Other verifications and audits are carried out on a case-by-case basis. To help business lines and divisions implement the methodology, the Group has run pilot projects on preventing social risks in subcontracting (see page 249, “Preventing social risks in subcontracting in France”).
In respect of temporary employment agencies, the Group’s Purchasing Coordination unit has set up a framework agreement to select approved agencies. The non-financial criteria used to assess them relate to occupational health and safety, training, diversity, the prevention of illegal and undeclared work, and the existence of a whistleblowing system for employees. In France, it is compulsory for Group entities to use approved agencies to recruit their temporary workers. Agency-specific improvement plans have been developed on a case-by-case basis (see also paragraph 4.2, “Duty of vigilance with regard to health and safety”, page 234). During the latest agency selection process, 23% of those assessed were excluded based on ESG criteria. Beyond the selection phase, Group companies also put controls in place while contracts with agencies are ongoing to prevent risks of infringing workers’ rights. For example, controls are carried out on payroll systems, to ensure that all hours worked are paid, and on the full reporting and payment of social contributions to accredited organisations, to ensure that workers access the social benefits to which they are entitled. These items are also verified during subsidiary assessments.
For purchasing categories that are shared by all business lines, that significantly impact revenue, or that involve significant non-financial risks, specific CSR assessments are conducted with the Group’s Purchasing Coordination unit. The purchasing category is analysed in depth and the associated social risks are mapped. Invitations to tender and specifications integrate social criteria, based on identified issues. Depending on how they perform against the criteria, some suppliers may be discarded, while for others, a CSR improvement plan may be proposed, with the aim to promote collective upskilling (see also paragraph 2.2, “Relations with suppliers and subcontractors”, page 197).
