VINCI has used its experience in Qatar to enhance internal practices and policies in all its operations. The Group strives to provide its teams with operational guidelines. Accordingly, it has translated the risk of forced labour into more concrete factors: the risk of recruitment fees and debt; the risk of employment contract substitution and the risk of confiscation of workers’ working permits, identity documents, visas, and passports. The guidelines also cover risks relating to working conditions (wages, working hours, etc.), accommodation and value chain practices. All of the tools developed to implement the Group’s human rights policy, from risk maps to assessment scorecards, address these risk factors. The Group is also developing training courses based on case studies to train managers in detecting and preventing the risk of forced labour. VINCI keeps a close eye on any new tools developed by human rights organisations that may be useful to companies in the Group. For example, in 2021 VINCI tested the Cumulus platform designed by the NGO Verité for several of its operations. It helps companies to identify forced labour risks in supply chains, including in the construction industry. As a member of the Leadership Group for Responsible Recruitment (https://www.ihrb.org/employerpays/leadership-group-for-responsible-recruitment), VINCI also participated in its reporting process on recruitment practices and the risk of forced labour in all its operations.
The issues faced by VINCI are not limited to regions outside of France. Tensions in the building and civil engineering markets, combined with increased competition and labour flows in Europe, have led the Group to strengthen its duty of vigilance with regard to preventing social risks and illegal work in its supply chain in France. In 2018, VINCI introduced new measures to further reinforce its risk prevention and launched several pilot projects in construction businesses in the Greater Paris area. These enhanced measures were gradually rolled out in a broader mix of business activities.
The methodology followed involves three phases:
Managers were involved at all levels, from the head office to worksites (including functional directors, regional directors, business unit heads, works managers, works supervisors, team leaders, etc.). The work was conducted across the main support functions (such as human resources, legal, purchasing and risk prevention) and in collaboration with employee representatives. VINCI Construction France formed a steering committee at its top management level. In all, several hundred participants in the chain of operations contributed their input to the diagnoses. Each regional division was asked to develop a responsible subcontracting policy, tailored to its business activities, organisation, local issues and the region’s socio-economic situation, and build an action plan covering the entire subcontracting process, from the initial decision to subcontract, to selecting the subcontractor, to assessing the subcontractor’s performance after completion of the work.
To support these efforts, a solution was developed to help maintain a database of reliable subcontractors. Works managers can use it to assess the subcontractors employed at their worksites against a shared set of criteria, which incorporates social risks. Assessments entered by other departments can also facilitate the initial selection of a subcontractor. This data sharing enables VINCI companies to take a more consistent approach to their work with subcontractors, quickly issue warnings in the event of a risk or nonconformity and support them as needed.
Social audits of subcontractors at worksites have been carried out since 2019. The audit procedure has been adapted to different types of worksite – for example, major projects conducted as joint operations, smaller worksites fully controlled by VINCI, or worksites in the launch or finalisation phase. During these audits, overseen by external auditors, particular attention is given to aspects involving the on-boarding and management of subcontractor employees, such as employment contracts, payment of wages and compliance with obligations in respect of working time and health and safety. Feedback from the audits serves to fine-tune prevention initiatives and, if applicable, update the risk map or assessments of partner companies. Follow-up audits are launched to ensure that action plans are being carried out and continue to provide support to operational teams, who are demonstrating more and more knowledge of these issues.
To strengthen in-house skills in this area, in 2021, VINCI developed a toolkit for use in training its teams in conducting social audits of subcontractors. The Group’s goal is to continuously monitor subcontractors associated with higher risks, while also expanding social auditing practices. The training of in-house trainers will begin in 2022. The toolkit they receive includes resources such as a guide to the methodology, an auditing scorecard, an interview scorecard for interviews with employees of subcontractors, a standard audit plan, standard letters for communicating with subcontractors and other documents.
VINCI Immobilier has joined these efforts to prevent social risks in subcontracting in France. The three-phase methodology was adapted to its status as a project owner. The results of the preparatory work and the associated action plan were presented to the management committee at the end of 2020. Implementation is in progress.
The methodology and its results were shared with professional organisations and certain customers and project managers with which VINCI companies work in France. In 2020 and 2021, VINCI also held discussions with representatives of Syndex, commissioned by the European Federation of Building and Woodworkers (EFBWW). The aim was to develop a toolkit to empower European Works Council representatives to monitor compliance with employment and social protection rules in construction industry supply chains.
One of the main challenges in the fight against forced labour is its complexity, which requires collaborative, multi-party action by governments, businesses, international organisations, labour unions, NGOs, professional organisations, etc. to comprehensively address the issue. Although VINCI is a large company, its position in the value chain and its volume of activity in a given country or project is often limited, which can lessen its degree of local influence. Due to the inherent characteristics of the risk, in addition to those of the construction industry, VINCI strives to share its practices and challenges with the business community and the industry as a whole, to promote responsible recruitment and help create a virtuous ecosystem.
