Based on this risk map, VINCI developed VINCI’s Guide on Human Rights (https://www.vinci.com/publi/manifeste/vinci-guide_on_human_rights-en.pdf), which forms the backbone of its work in this area. It presents guidelines to be followed by the Group’s entities, all businesses and countries combined, for each issue and theme. These guidelines cover the entire project life cycle, from the response to the call for tenders to the preparation of sites and construction, until the commissioning and operating phases. They were designed to be adapted to the on-the-ground reality of each sector and activity, so that entities can anticipate risk factors as early as possible and design practical responses to prevent human rights risks. The guide is distributed with an annexe describing the main issues in detail, explaining the challenges involved and offering concrete recommendations and best practices to better support employees.
This framework document, available on the VINCI website, was validated by the Group’s Executive Committee in April 2017, after consulting with the European Works Council, which approved the policy. The implementation of human rights policy is presented annually to the Board of Directors’ Strategy and CSR Committee and discussed with the European Works Council.
It has been broadly disseminated to employees and presented to every management committee in the Group’s business lines and divisions, and continuous efforts are made to build awareness. VINCI’s internal control survey for 2022 showed that by the end of September, 94% of the entities surveyed, all business lines and divisions combined, had communicated about the Guide to their employees. To facilitate the adoption and dissemination of the guidelines, the guide has been translated into 23 languages, thereby covering more than 98% of the Group’s workforce, based on the official languages of the countries where the Group operates.
94 %of entities in VINCI’s internal control survey have disseminated VINCI’s Guide on Human Rights
The Group’s Human Resources Director, who is a member of the VINCI Executive Committee, pilots human rights policy with the support of the Group’s top management and the Human Rights Steering Committee, which facilitates decision-making, discussion and collaboration among the Group’s business lines and divisions. Members keep their respective management committees informed and are in charge of disseminating and rolling out policy in their respective business lines and divisions. At every meeting, the steering committee assesses the progress made regarding the human rights component of the duty of vigilance plan. The teams working in the field to ensure the respect of human rights are primarily the Group’s human resources professionals, as well as its operational managers, who occupy key roles in the Group’s organisation and uphold the Group’s commitments inside companies and projects.
The implementation of human rights policy is coordinated on a continuous basis by the Corporate Social Responsibility (CSR) Department, reporting to the Human Resources Department. The CSR Department shares its expertise with business lines and divisions to help them incorporate and implement Group measures, develop risk-mapping and assessment tools, evaluate subsidiaries, train and build awareness among employees and management committee members and communicate with Purchasing, Internal Control, Ethics and Vigilance, Security, Health and Safety Coordination and other departments. The team is in frequent contact with interested external parties to address identified issues, answer questions and provide further information about the measures taken in the Group.
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 introduced a whistleblowing system for raising concerns about human rights. 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 265).
An understanding of the local context is essential to determining which issues are most relevant and conducting appropriate preventive actions. 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.
