2021 UNIVERSAL REGISTRATION DOCUMENT

4.5 The Group’s system for whistleblowing, alerts and the processing of reports

The Ethics and Vigilance Department supports the implementation of the Group’s compliance programmes, in addition to procedures for raising concerns in specific areas of risk. It is responsible for VINCI’s whistleblowing system (see paragraph 2.4, “Business ethics”, page 201) and reports to the Group’s Executive Management.

• A procedure available to all stakeholders

The Group has set up a unique whistleblowing system, called VINCI Integrity, which can be used by any concerned person to report any serious irregularities relating to the work context, and of which they have personal knowledge. The persons covered by the whistleblowing procedure are:

• - employees of companies in the VINCI Group;
• - external or temporary employees of companies in the VINCI Group (such as temporary staff or employees of subcontractors, suppliers, service providers, etc.);
• -  persons who are stakeholders in a project, for subjects relating to duty of vigilance in the environmental and social domains.

•  A procedure addressing all areas of concern

Whistleblowing in the work context may involve the following areas:

• - behaviour or a situation that infringes VINCI’s Code of Ethics and Conduct or its Anti-corruption Code of Conduct;
• - behaviour or a situation that infringes VINCI’s Guide on Human Rights or violates human rights and fundamental freedoms;
• - behaviour or a situation that infringes VINCI’s “fundamental and essential workplace health and safety initiatives” or will have a severe impact on people’s health and safety;
• - behaviour or a situation that infringes VINCI’s environmental commitments or will have a severe impact on the environment.

•  A multimodal procedure

Multiple, complementary channels are available for processing reports. Whatever the means used, all exchanges are kept strictly confidential.

Employees inform their direct or indirect supervisor, or an officer designated for this purpose within the entity to which they belong. Employees can use the whistleblowing system available in their entity, contact the Group’s Ethics Officer directly, or use VINCI Integrity, the Group’s whistleblowing platform. VINCI guarantees that no employee will be disciplined, dismissed, or retaliated against in any way, whether directly or indirectly, for having reported or given evidence, under the whistleblowing procedure and in good faith, concerning acts of which the employee obtained personal knowledge during the course of their duties. This remains the case even if the allegation made is determined to be false after investigation. Similarly, the identity of the accused person is treated with the utmost confidentiality.

External stakeholders can access VINCI Integrity from the Group’s website and report concerns.

These mechanisms ensure a reliable, highly secure method of reporting with end-to-end traceability.

5. Note on the methods used in workforce-related, social and environmental reporting

VINCI’s workforce-related, social and environmental reporting framework complies with Articles L.225-102-1, R.225-104 and R.225-105 of the French Commercial Code, as well as Order 2017-1180 and Decree 2017-1265. It uses the Global Reporting Initiative (GRI) standards as a basis for organising, analysing and prioritising risks and for assessing workforce-related, social and environmental impacts – see the cross-reference table on page 375.

5.1 Methodological procedures

VINCI’s procedures are specified in the materials listed below.

• For workforce-related indicators:

•  - a guidebook in four languages (French, English, German and Spanish) containing workforce-related indicator definitions;
•  - a methodological guide to VINCI’s workforce data reporting system, including a reporting tool users’ manual in four languages (French, English, German and Spanish);
•  - a guide to consistency checks in two languages (French and English);
•  -  an audit guide helping entities to prepare for audits and make good use of their results (available in French, English, German and Spanish).

•  For environmental indicators:

•  - a methodological guide to VINCI’s environmental reporting system, including a guide to the definition of common indicators, which entities can use to set up their environmental reporting procedures. This guide is available in three languages (French, English and Spanish);
• - a reporting tool users’ manual in two languages (French and English);
•  - an audit guide helping entities to prepare for audits and make good use of their results (available in French and English);
•  - a guide presenting six methods that can be used to estimate data for the last months of 2021 in the context of the fast close process.

All of the above materials are accessible on the Group’s intranet site.