2022 Universal Registration Document

Key Data

VINCI’s commitment to human rights is reflected in specific actions that are closely aligned with its operations and tailored to the level of risk. In Qatar for instance, where VINCI is present through Qatari Diar VINCI Construction (QDVC), employment and working conditions have been monitored more closely, particularly for employees of temporary employment agencies and subcontractors. This is presented on the Group’s website: https://www.vinci.com/vinci.nsf/en/item/qatar-en.htm. Further details on the actions taken can be found in paragraph 4.3.7, “Reinforced vigilance to fight forced labour and illegal work”, of the Group’s duty of vigilance plan, page 268.

Tools developed by VINCI to “protect, respect and remedy” (*) the potential human rights impacts relating to its activities
  • VINCI’s Guide on Human Rights and its Supplement: a set of operational approaches and guidelines to be adopted for all VINCI activities in all the countries where it operates.
  • Human rights e-learning module: a course to raise awareness and train employees on the Group’s commitment to human rights, the scope of its responsibilities, the human rights risks associated with its business lines and the possible repercussions of human rights violations.
  • Country risk maps: analysis designed to help VINCI and its subsidiaries to identify and prioritise areas in which there are specific human rights risks linked to the regulatory, political, economic, social and environmental context in a given country.
  • Managing Human Rights: a human rights performance tool, with over 200 questions to carry out an objective, in-depth and qualitative assessment of entities, and to put in place corrective actions on aspects such as recruitment, working conditions, living conditions, subcontracting and the local community impacts of projects. This tool was rolled out in 2018 and has been available to all employees on the intranet since 2022, with three different languages to choose from.

(*) United Nations Guiding Principles on Business and Human Rights: https://bit.ly/3KB625L.

2.4 Business ethics

2.4.1 General approach to business ethics
  • Integrated, cross-business approach, supported at the highest level within the Group

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:

  • the Code of Ethics and Conduct, which sets out the rules of conduct for all Group companies and employees;
  • the Anti-corruption Code of Conduct, which lays down the rules for the prevention of acts of corruption, notably by identifying the corruption risks in business processes and illustrating the behaviours and practices to be avoided.

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.

  • Structured governance framework

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:

  • preventing corruption;
  • preventing serious violations of human rights and fundamental freedoms, harm to human health and safety, or damage to the environment resulting from Group activities.

It oversees changes to the Code of Ethics and Conduct and the Anti-corruption Code of Conduct, and met four times in 2022.

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 and compliance heads from 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 four times in 2022.

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 four times in 2022, is supported by a network of correspondents in the business lines.

  • Continuous improvement approach

VINCI has decided to deploy extensive resources with a view to continuously improving its anti-corruption measures and reinforcing its prevention of these risks.