(*) The 2022 action plan is based on data at 31 December 2021, not including data for Cobra IS.
VINCI considers that in matters of human rights, leaders play a decisive role. The Group places emphasis on awareness and training initiatives for managers and employees. It aims to foster a culture of human rights risk prevention, as it has done in the area of safety, and provide tools to help operational teams take preventive action as early as possible.
To raise awareness of human rights risks, an e-learning course in five languages (English, French, Polish, Portuguese and Spanish), resulting from a year of collaborative in-house development, has been open to all entities and employees since 2019. It primarily addresses managers and those in charge of human resources, administration, finance, and health and safety. Completion is monitored and reported to the Human Rights Steering Committee. At the end of 2022, close to 16,500 employees in the target groups, in nearly 90 different countries, had finished the course (4,000 employees in 70 countries in 2021). A complementary course for managers of concessions has been developed since last year. It delivers an interactive presentation of the issues that may arise during a project’s three phases: development, design and construction, and operation and maintenance. In addition, several of the Group’s well-established, emblematic training programmes now include a human rights component. One example is Team Grands Projets, a training course shared by all VINCI Construction divisions, designed to build the skills of managers of major projects and help them handle complex environments more effectively.
The CSR Department team also provides in-person training, on a continuous basis, to many management committees and employees of Group entities. At these sessions, the team members present the Group’s human rights issues and risk management tools available and explore more specific topics such as minimum social protection, the living wage, or the latest regulatory updates on the duty of vigilance and supply chains.
The Group also upholds its commitments by providing multiple channels by which employees can report concerns. These channels include contacting human resources departments, health and safety representatives, line managers or employee representative bodies. If confidentiality is a concern, employees can also approach the ethics officers of the Group’s business lines and divisions or at Group level.
Apart from the whistleblowing system at Group level (see paragraph 4.4.4, “The Group’s whistleblowing systems”, page 281), due to VINCI’s multi-local organisation and the nature of its activities, it also encourages the implementation of local procedures for reporting concerns. The Group’s view is that whistleblowing systems and alert procedures are more effective when they are local, since the company, project or worksite is then better positioned to proactively handle reports, including those by end users and local residents, identify any weak areas and reinforce prevention. A number of Group companies have set up additional channels, other than the line manager, to report complaints or situations that present a risk, such as a human rights risk. These may be dedicated email addresses, hotlines or digital solutions. 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 Vía 40 Express in Colombia. In the Gulf countries, such as Qatar and the United Arab Emirates, specialised CSR coordinators are in charge of receiving any worker complaints, from direct and indirect employees, as well as maintaining a log and ensuring that the identified problems are quickly resolved.
Although VINCI entities are sometimes the customer, 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 Managing Human Rights platform is used to evaluate whether the management systems implemented by subsidiaries 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. The entity or project then reports on the results and improvement plan 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.
When Group entities launch their assessment on the Managing Human Rights platform, they are asked some 200 questions. For example: Has the company checked that the workers did not have to pay a recruitment fee? Has it checked that temporary workers and subcontractor employees on its sites are not working excessive hours? Has it ensured that there are systems in place to inform and consult local residents and communities that could be impacted by projects? The questions are precise, concrete, and relate to the five salient human rights issues and 17 themes. The four response options range from “no practices” (Level 1) to “best practices” (Level 4). Any Level 1 or Level 2 answer to one of the 50 items considered to be a critical human rights issue automatically flags the latter as a priority. After the assessment – preferably carried out as a group exercise, involving all relevant managers and employees – the entity has a comprehensive view of its human rights practices and can use it to build an effective action plan.
