A similar approach was taken in 2021 for acquisitions. Prior to new acquisitions, a risk assessment must be conducted to examine such aspects as the country of operation, the company’s commitments and the resources devoted to preventing human rights risks. This information is reviewed by risk committees whenever certain thresholds defined by the Group are exceeded.
In VINCI’s businesses, whether in concessions, energy or construction activities, the major challenges are at the operational level. Accordingly, when it comes to vigilance with regard to human rights risks in the value chain, priority is given to subcontractors, service providers and temporary workers employed at worksites and operating sites.
The Group has provided all entities with a due diligence methodology that includes the following steps: mapping human rights risks for subcontractors and service providers, applying specific criteria during the selection phase, including specific clauses in contracts and monitoring compliance with contractual obligations. Likewise, subsidiaries can use the Managing Human Rights tool to assess their knowledge of the working and employment conditions applied by the subcontractors and temporary employment agencies with which they collaborate. The platform also enables them to evaluate how they manage social risks in subcontracting and temporary employment. Verifications and audits are carried out on a case by case basis. To help business lines and divisions implement the methodology, the Group is introducing new measures to prevent social risks in subcontracting (under paragraph 4.3.7, “Reinforced vigilance to fight forced labour and illegal work”, see “Preventing social risks and illegal work in subcontracting in France”, page 278).
In respect of temporary employment agencies (TEAs), the Group’s Purchasing Coordination unit has set up a framework agreement to select approved agencies, which must be used by VINCI’s companies in France. The framework agreement was renewed in 2023. During the renewal process, assessed TEAs answered a mandatory sustainability questionnaire with six separate sections: recruitment and employment conditions, occupational health and safety, non-discrimination, training and skills development, preventing illegal or undeclared work, and the existence of a whistleblowing system. Audits were also performed for 14 of the agencies, prompted by their slightly unsatisfactory questionnaire results or by alerts received by the Purchasing Coordination unit. In all, 43 of the 144 TEAs assessed were excluded on the basis of ESG criteria or audits. A new contract was signed with 89 TEAs for 2023 to 2025. For 24 of these TEAs, an ESG improvement action plan was established. Such action plans are monitored by the Group’s Purchasing Coordination unit (see paragraph 4.2, “Duty of vigilance with regard to health and safety”, page 266). Beyond the selection phase, Group companies also put controls in place while contracts with agencies are ongoing to prevent risks of infringing workers’ rights. For example, controls are carried out on payroll systems, to ensure that all hours worked are paid, and on the full reporting and payment of social contributions to accredited organisations, to ensure that workers access the social benefits to which they are entitled. These items are also verified during subsidiary assessments.
For other purchasing categories that are shared by all business lines, that significantly impact revenue, or that involve significant non-financial risks, specific CSR assessments are conducted with the Group’s Purchasing Coordination unit. The purchasing category is analysed in depth and the associated social risks are mapped. Invitations to tender and specifications integrate social criteria, based on identified issues. Depending on how they perform against the criteria, some suppliers may be eliminated, while for others, a CSR improvement plan may be proposed, with the aim to promote collective upskilling (see paragraph 2.2, “Relations with suppliers and subcontractors”, of the “Social performance” section, page 215).
The issues facing VINCI and its entities are often complex and involve multiple players throughout the value chain. Although VINCI continually enhances its risk prevention and management systems, it does not always have the necessary leverage to pursue every possible action, due to its position in the value chain and the cyclical nature of its activities. Although VINCI is a large company, certain features of its businesses, the position occupied by Group companies in the value chain, and the fact that their volume of activity in a given country or project is often limited may lessen its degree of local influence. For this reason, as a complement to its in-house efforts, VINCI has joined a number of external coalitions and initiatives, collaborating with other stakeholders to develop tools, methodologies and actions to promote human rights, better address challenges and help build a more virtuous ecosystem.
