Through its CSR Department, the Group monitors and reports on policy implementation in its operations and conducts audits as required. Outcomes are presented to the Group’s top management, the Board of Directors and the European Works Council.
In some cases, the Group arranges for independent audits or other external controls of the management of major risks.
This is the case in Qatar, where a framework agreement (https://www.vinci.com/commun/communiques.nsf/04438CA8C4A62422C12581 DF00384D96/$file/Accord-cadre-En.pdf) was signed by VINCI, its subsidiary Qatari Diar VINCI Construction (QDVC), and Building and Wood Workers’ International (BWI). It provides for a control and audit system under the aegis of a reference group composed of representatives of the three parties. The agreement covers human rights in the workplace, accommodation, and issues relating to the fair recruitment and the labour rights of workers. It applies to all workers employed by QDVC in Qatar, including subcontractors and temporary workers. The latest audit of the implementation of the agreement took place in October 2021 with all parties present. As in 2019, VINCI’s trade union representatives were invited to participate. The audit covered all items in the agreement and the audit report was published in early 2022.
With regard to its airport activities in Cambodia, in 2018, VINCI commissioned an audit of psychosocial risks from an independent body, along with new audits of three main temporary employment agency partners. These measures were taken following mediation by the French National Contact Point (NCP) regarding implementation of the OECD Guidelines for Multinational Enterprises. The NCP found that the Group respected the OECD Guidelines in a complex national context and had taken appropriate due diligence measures for its Cambodian subsidiary. The Group continues to monitor the situation alongside its subsidiary and the NCP.
In addition, especially for major projects, the Group employs independent service providers to assist teams in assessing human rights risks and designing measures to mitigate impacts.
VINCI’s internal control system has been expanding its focus to increasingly include human rights. The Group may thus carry out unannounced verifications of compliance with the rules set out in its reference documents, as a complement to the controls put in place by business lines and divisions. The audits led by VINCI’s internal control team may include customised questions relating to human rights issues, developed in collaboration with the CSR Department.
VINCI added a section on preventing human rights risks to its annual internal control survey five years ago. The survey aligns with the requirements of the reference framework published by the Autorité des Marchés Financiers (AMF, the French securities regulator), which states that parent companies must ensure that subsidiaries have risk management and internal control systems. Survey findings are presented to the heads of internal control, the members of the Human Rights Steering Committee and the members of the Group’s Board of Directors and shared with the Group’s business lines and divisions. The Group also uses the survey results to adapt or reinforce certain initiatives.
The order of priority for subsidiary audits, conducted by the CSR Department and evaluators in business lines and divisions, is determined based on a consolidation of eight internationally recognised indicators (*) and the strength of the presence (workforce and revenue) of VINCI’s companies in a given country. Priority is given to assessing subsidiaries in countries where the Group’s presence is strong and human rights are deemed to be at risk. Because some VINCI company activities are project-based, this ranking and the accompanying road map are reviewed each year to account for changes in their geographical locations, level of activity, and external indicators. The steering committee monitors progress in implementing the road map. If needed, other country analyses may be developed to better identify potential issues and risks when preparing a response to a call for tenders.
(*) World Bank, Worldwide Governance Indicators – Rule of Law; Transparency International – Corruption Perceptions Index; United Nations Development Programme (UNDP) – Human Development Index; World Economic Forum – Global Gender Gap Report; US Department of State – Trafficking in Persons Report; Ratification of International Labour Organisation (ILO) – Eight fundamental conventions; Freedom House – Freedom in the World report; International Trade Union Confederation (ITUC) – Global Rights Index.
