2023 UNIVERSAL REGISTRATION DOCUMENT

General and financial elements

  • Whistleblowing systems for raising concerns

The Group also upholds its commitments by providing multiple channels through 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 4.5, “The Group’s whistleblowing systems”, page 290), 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 in the organisation and reinforce its preventive measures.

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, VINCI Construction in the Czech Republic and Slovakia, and Vía Sumapaz 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 problems raised 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.

These whistleblowing systems and the examination of the concerns that are raised also contribute to the identification and analysis of areas where VINCI must be vigilant.

4.3.4 Assessing the situation of subsidiaries, subcontractors and suppliers
  • Managing Human Rights, a tool to assess subsidiary practices

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 at Group level. The assessments are carried out by the Social Responsibility Department or by specially trained staff in business lines and divisions. 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 the hours worked by temporary workers and subcontractors’ employees on its sites are accurately recorded and that social contributions are fully paid? 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 (see paragraph 4.3.1, “Major risk identification and analysis”, page 269). 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 issue automatically flags the latter as a priority. In most cases, an assessment is carried out over several days and involves collaborative group sessions bringing together operational managers and members of the management committee of the entity or project. Visits are also made to examine sites and worker accommodation, and interviews may be conducted with employees, temporary workers and/or subcontractors and their employees, to cross-check the information obtained. After completing the assessment, the entity has a comprehensive view of its practices and can build an effective action plan. In 2022, following updates to reflect user experience and critical feedback from several corporate and human rights experts, a finalised version of the digital tool was released on the vinci.net intranet for use by all Group employees, in English, French and Spanish. VINCI has made the platform open to its 280,000 employees, to encourage them all to engage with the issues and communicate them widely. Managing Human Rights is an essential component of VINCI’s efforts to promote human rights.

  • Risk assessment ahead of new projects or company acquisitions

While rolling out the Managing Human Rights assessment platform, the Group also worked to identify and address issues before the start of a project   during the bid preparation stage – especially for large projects. In 2023, the Audit and Internal Control Department supervised the review and validation of the risk scorecard for the Construction and Energy businesses, along with the accompanying explanatory note, with the input of the Environment Department and the Ethics and Vigilance Department. The scorecard and note are among the documents that must be presented to the VINCI Risk Committee for approval before submitting a bid to the client. They now include an expanded section focusing specifically on social and environmental risks, alongside technical and financial risks. For example, the human rights risks items cover the management of impacts on local communities and nearby residents and the rights of direct and indirect employees. In addition to the scorecard to be presented to the VINCI Risk Committee, a separate environmental and social questionnaire with 44 items, complete with an explanation of the various aspects to be considered, was developed to help the teams in charge of the bid to identify the risks and issues that could impact the project (due to the local or operational context or the type of services to be provided) and enable them to anticipate the necessary measures and take them into account, either by adjusting the project’s resources and means or by redefining the services to be provided. In 2024, based on the results of the initial tests performed, awareness training will be rolled out for the teams in the Group’s various entities who are responsible for responses to calls for tenders.