2023 UNIVERSAL REGISTRATION DOCUMENT

General and financial elements

Continuous improvement approach

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

2.4.2 Business ethics measures put in place

Training and information

Training and information are key factors for implementing the Group’s business ethics policy. To enable all employees to effectively contribute to preventing and detecting corruption, depending on their duties and responsibilities, specific training programmes are developed and rolled out at each of the Group’s organisational levels. These programmes ensure that employees understand the related domestic and even international legal frameworks, and identify the issues and responsibilities involved. They explain the corruption scenarios identified and the risks involved, the steps to be taken to reduce these risks, the recommended behaviours when faced with solicitations and the procedures for reporting inappropriate conduct, as well as the disciplinary actions that may be taken or the criminal penalties that may apply to individuals for any infringement of rules or regulations. As exemplary managerial behaviour is essential to effectively spearhead ethical practices within its subsidiaries, the Group’s conduct guidelines are covered in all of the management training programmes provided by the academies.

79,000

staff trained on ethics

The Ethics and Vigilance Department regularly gives presentations for manager events (conferences) and cross-business network meetings, such as human resources, communications, tax expert, purchasing, insurance or finance seminars, as well as the Pivot Clubs.

VINCI’s anti-corruption system
Engagement of key managers

Engagement of key managers

Anti-corruption Code of Conduct

Anti-corruption Code of Conduct

Information and training

Information and training

Risk assessments

Risk assessments

Accounting controls

Accounting controls

Internal audits

Internal audits

Whistleblowing system

Whistleblowing system

Whistleblowing system

All employees have access to several channels for reporting their concerns. They can refer matters to their managers, use their business unit’s local whistleblowing system or directly contact the Chief Ethics and Vigilance Officer at Group level. They can use the VINCI Integrity platform to submit whistleblowing reports concerning infringements of the Group’s rules and commitments set out in the reference guides on human rights, health and safety, business ethics and the environment.

This platform is also available to external stakeholders via the Group’s website.

Risk assessments

The assessment of business ethics-related risks is an integral part of the policy for managing risks that might affect the Group’s overall performance or image. The findings of this assessment, based on a collaborative process and carried out by working closely with the teams on the ground, are mapped and the risks identified are ranked in relation to the relevant organisational level. It is incorporated into both the project analysis process (Risk Committee) and the external growth process (Investment Committee). Key customers, suppliers and subcontractors, as well as any commercial intermediaries, are assessed before the Group starts doing business with them and/or during their contractual relationship thanks to various measures, including multidisciplinary questionnaires and specific platforms.

Accounting controls and audits

The accounting processes put in place help prevent corruption. The internal audit plans and self-assessment processes, overseen by the finance teams, include a series of questions aimed at ensuring the existence and effectiveness of the arrangements for preventing corruption.

Group GDPR maturity

With regard to personal data protection, VINCI drew on the GDPR (General Data Protection Regulation) maturity audit carried out in 2021 to continue rolling out its action plan in 2023 aimed at further strengthening compliance in the areas for improvement identified.