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 (www.vinci.com/vinci.nsf/en/press-releases/pages/20171121-1200.htm) 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’ employees and temporary workers. The most recent compliance audit 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. Especially in the context of a major project, the Group sometimes employs independent service providers to assist teams in assessing human rights risks and designing impact mitigation early on, for example, during bidding or the preparation phase once a contract has been awarded. This occurred recently in Indonesia, Senegal and Kenya.
VINCI’s internal control system has been expanding its focus to increasingly include human rights. In addition to reinforcing risk committee reviews of environmental and social risks, and as a complement to the controls performed by business lines and divisions, the Group may initiate unannounced verifications of compliance with the rules set out in its reference documents. The audits led by VINCI’s internal control team may include customised questions relating to human rights issues, developed in collaboration with the Social Responsibility Department. In 2023, a representative of the Audit and Internal Control Department participated in a human rights assessment conducted by the Social Responsibility Department. The audit thereby combined both departments’ approaches. More joint audits will be carried out in 2024. Lastly, VINCI added a section on preventing human rights risks to its annual internal control survey six 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. In 2023, the questions covered topics such as the dissemination of VINCI’s Guide on Human Rights, participation in the e-learning course, and human rights risk awareness, but also collected data on employees’ working hours or the verification by subsidiaries of the working conditions of temporary workers and subcontractors’ employees. Survey findings are presented to the heads of internal control, the members of the Human Rights Steering Committee and the members of the Board of Directors and shared with the business lines and divisions. The Group also uses the survey results to adapt or reinforce certain initiatives.
Besides carrying out additional assessments of human rights compliance, the Group monitored certain action plans in 2023, such as those of entities located in high-priority countries. In Benin, the human rights assessment helped one entity to formalise a recruitment procedure for local workers. The procedure now provides a clear and detailed description of the onboarding process, working conditions and internal rules on taking leave. Similarly, in Côte d’Ivoire, workers’ contracts now contain more comprehensive information about certain rights and applicable working conditions. In Colombia, a communications plan was developed to warn applicants against false promises of employment coming from persons outside the company. Measures to audit subcontractors’ employment practices have been gradually reinforced. Several assessments this year prompted subsidiaries to update their action plans with items such as revising contract templates to include new clauses to manage social risks. These clauses hold subcontractors to a higher standard than local labour law and/or apply requirements to a wider range of partners. These action plans also generally provide for the development and implementation of measures to verify compliance with employment-related criteria, in particular for the categories of subcontractors or service providers that present the highest risk. Some Group entities – in Brazil, Gabon, Togo and Indonesia, for example – were already preventively checking key labour law points with their subcontractors’ employees, prior to the rollout of human rights assessments. They were encouraged to implement these checks more widely, conduct them more frequently, or increase the number of items verified. In Indonesia, the human rights assessment revealed a critical nonconformity by a subcontractor. The entity’s active engagement with this issue enabled the subcontractor’s employees to obtain the retroactive pay they were owed under applicable law (see also “Risk prevention in Qatar”, page 276, under paragraph 4.3.7, “Reinforced vigilance to fight forced labour and illegal work”, for more remediation examples). The assessed subsidiaries also developed or enhanced their whistleblowing systems, with various aims: improving workers’ awareness of the system, applying it more explicitly to human rights concerns, opening it up to subcontractors and service providers working on a site, or making its rules of use more transparent, for example. Preparing for an assessment sometimes led subsidiaries to enrich their employee surveys with questions about working conditions or to visit workers’ accommodation to ensure that it met the applicable standards. In Senegal, a checklist was developed to evaluate the condition of housing rented by the company near a worksite. In Turkey, human rights compliance assessments created an opportunity for teams to review the applicable standards, establish a set of assessment criteria and collaborate with the health and safety network. In Brazil, for a project at a remote location, the decision was made to no longer house workers in temporary group accommodation but to rent homes for them near the worksites. Recommendations to improve the quality of locker rooms or provide access to secure lockers were applied. The increased number of assessments is encouraging subsidiaries to share practices and feedback more actively. Following an assessment, the recommendations made are closely tailored to subsidiaries’ practices to ensure that the corrective actions are effective in their operational context. For example, a subsidiary may be advised to incorporate social risk prevention into the checklists used by their managers for site inspections or into the mobile applications that have already been developed for health and safety visits, rather than create a new tool.
