Generally speaking, all entities performed follow-up audits, took corrective action and improved recruitment practices, working conditions and workers’ accommodation after being assessed. The entities also formalised certain processes and showed a greater awareness of the risks related to the potential impacts of VINCI’s activities on local communities.
The Group has long been committed to the fight against forced labour. Because forced labour is such a serious risk, VINCI is particularly aware that special scrutiny must be paid to the conditions in which migrant workers are recruited and employed, whether directly or indirectly, via temporary employment agencies or subcontractor companies.
The underlying factors driving forced labour can vary from region to region. VINCI considers that this issue must be handled close to where the problem occurs in order to take effective actions that are adapted to the on-the-ground realities. The risk of forced labour can come from certain legislative frameworks that do not align with international conventions or arise from unfair local practices, which are sometimes deeply embedded. Many problems may arise early in the recruitment phase, even before workers arrive at the project site or are hired by the Group.
The risk intensifies when an activity depends on a high volume of low skilled workers or where labour migration flows are significant. Some workers migrate to another country to seek higher wages, and the construction sector offers attractive job opportunities. Although VINCI promotes local sourcing of labour, Group companies may recruit migrant workers to meet their businesses’ needs in certain regions, mainly due to local labour shortages. Once workers migrate for work, they become dependent on their employer not only for their employment but also with regard to their living conditions and accommodation. They are more vulnerable than other workers and face a greater risk of exploitation. This risk is amplified if they do not speak the language of the host country, are unfamiliar with cultural norms or have a limited understanding of their rights.
VINCI has used its experience in Qatar to enhance internal practices and policies in its operations. The Group strives to provide its teams with operational guidelines. Accordingly, it has translated the risk of forced labour into more concrete factors: the risk of recruitment fees and debt; the risk of employment contract substitution and the risk of confiscation of workers’ working permits, identity documents, visas, and passports. The guidelines also cover risks relating to working conditions (wages, working hours, etc.), accommodation and value chain practices. All of the tools developed to implement the Group’s human rights policy, from risk maps to assessment scorecards, address these risk factors. The Group is also developing training courses based on case studies to train managers in detecting and preventing the risk of forced labour. VINCI keeps a close eye on any new tools developed by human rights organisations. For example, the Group tested the Cumulus platform designed by the NGO Verité for several of its operations. It helps companies to identify forced labour risks in supply chains, including in the construction industry.
Therefore, in addition to reinforcing policies and internal practices within the Group, VINCI also shares its experience and engages with many different stakeholders to improve the industry’s practices as a whole.
VINCI is present in Qatar via Qatari Diar VINCI Construction (QDVC). Since 2007, QDVC has taken concrete measures to improve migrant worker’s living and working conditions and to prevent the risk of forced labour at every stage in the migration cycle. VINCI has created a dedicated page on its website to provide easy access to detailed information and documents on its initiatives in Qatar (www.vinci.com/vinci.nsf/en/item/qatar-en.htm).
To eliminate debt bondage and contract substitution, which are major contributing factors to the vulnerability of migrant workers in Qatar, QDVC quickly set up processes to monitor recruitment agencies in countries of origin (Bangladesh, India, Nepal, etc.). It also provided clear rules specifying which costs are covered by QDVC, to prevent them from being passed on to workers. A full 100% of the contracts signed prohibit agencies from charging recruitment fees and include a reference to the Employer Pays Principle (www. ihrb. org/employerpays/the-employer-pays-principle) supported by VINCI, along with strict clauses to ensure its application, and the obligation to monitor downstream compliance. During recruitment campaigns, QDVC employees have visited agencies in home countries on several occasions to verify compliance with rules, reinforce messages to applicants that recruitment is free, examine the actual working conditions offered and participate directly in recruitment interviews. Currently, QDVC’s activity is in sharp decline, since most of the infrastructure projects attributed to the subsidiary are coming to an end. As a result, QDVC is not recruiting any more workers.
Regarding freedom of movement, all QDVC workers hold a Qatari residence permit, which is required to move freely within the country. They also have access to a safe in which they can store their personal documents (passports, employment contracts, etc.). If any worker chooses to leave employment, QDVC systematically issues a “no objection certificate” (NOC) enabling them to work for a different employer. Workers who wish to leave the country for a holiday, an emergency, or any other reason can do so with no barriers. These were already QDVC’s practices long before the Qatar government’s 2020 reform of the kafala (sponsorship) system.
QDVC carries out human rights audits of subcontractors and temporary employment agencies, during which it inspects sites, verifies records and documents and interviews workers. In 2023, QDVC conducted audits of its 144 Tier 1 and Tier 2 subcontractors and six temporary employment agencies on site at the end of 2023. Of these, 50 examined working conditions and 85 looked at living conditions. In addition to these audits, QDVC also conducts spot checks, during which its teams make unannounced on-site visits to verify that workers are in possession of their passport and a valid work permit, that they receive their salary in full in their bank account, that they have health insurance, that working hours are complied with, that their housing is satisfactory and that they did not pay a recruitment fee to come work in Qatar. These spot checks covered 150 workers employed by subcontractors in 2023.
