2023 UNIVERSAL REGISTRATION DOCUMENT

4.4.5 Monitoring measures put in place and their effectiveness

VINCI’s Environment Department, together with the Audit and Internal Control, Ethics and Vigilance, Social Responsibility, and Purchasing departments, supervises the work undertaken to monitor these environmental risk management measures and assess their effectiveness. This follow-up is performed on a continuous basis, through the coordination of internal committees focusing on each of the Group’s material environmental issues (the Environment Committee, the Biodiversity Task Force, and the Circular Economy Task Force). Monitoring and assessment are also carried out by the Group’s network of environment officers. Among other tasks, these officers respond to the annual environmental reporting questionnaire, which contains about 60 quantitative indicators based on Global Reporting Initiative standards (a common set of indicators to assess companies’ sustainable development policies), the recommendations of the Task Force on Climate-related Financial Disclosures (see the cross-reference table, page 411), the Taskforce on Nature-related Financial Disclosures (see the cross-reference table, page 411), and the Sustainability Accounting Standards Board framework (see the cross-reference table, page 412). The reporting process is an excellent resource for managing and following up on action taken to reduce the environmental risks relating to VINCI’s activities. It also incorporates some data on the subcontractors of VINCI companies.

This monitoring and assessment work accompanies the Group’s new environmental ambition, which aims to strengthen the commitments made by Group companies and sets targets for reducing the environmental footprint of their activities. These goals are regularly reviewed by VINCI’s Executive Committee and Board of Directors.

4.5 The Group’s whistleblowing system

The Ethics and Vigilance Department supports the implementation of the Group’s compliance programmes, in addition to procedures for raising concerns in specific areas of risk. It is responsible for VINCI’s whistleblowing system (see paragraph 2.4, “Business ethics”, of the “Social performance” section, page 219) and reports to the Group’s Executive Management.

A platform available to all stakeholders

The Group has set up a whistleblowing platform called VINCI Integrity, which can be used by any concerned individual to safely report irregularities relating to a work context.

Whistleblower protection applies to the following natural persons:

• employees of companies in the VINCI Group;
• former VINCI Group employees and persons having applied for employment in the VINCI Group;
• external or temporary employees of companies in the VINCI Group (such as temporary staff or people employed by suppliers or service providers);
• members of a board of directors or other management or supervisory body;
• shareholders, partners, or holders of rights to vote in VINCI’s Shareholders’ General Meeting;
• joint contractors of the VINCI Group and their subcontractors or, if these are legal entities, the members of the board of directors or other management or supervisory body of these joint contractors and subcontractors and their employees;
• natural persons who are stakeholders in a project, with regard to environmental or social vigilance.

A system covering all areas of concern

A whistleblowing report may pertain to the following concerns in a work context:

• an actual or foreseeable behaviour or situation that infringes VINCI’s Code of Ethics and Conduct or its Anti-corruption Code of Conduct;
• an actual or foreseeable behaviour or a situation that infringes VINCI’s Guide on Human Rights or violates human rights and fundamental freedoms;
• an actual or foreseeable behaviour or a situation that infringes the Group’s joint declaration (“Essential and Fundamental Actions Occupational Health and Safety”) or will have a severe impact on people’s health and safety;
• an actual or foreseeable behaviour or a situation that infringes VINCI’s environmental commitments or will have a severe impact on the environment;
• a crime;
• an infringement of, or an attempt to conceal the infringement of, an international commitment ratified or approved by France, a unilateral act of an international organisation based on such a commitment, European Union law, or any national law or regulation;
• a threat or harm to the public interest.

A system with multiple reporting channels

Several complementary channels are available for receiving reports. Whatever the means used, all communications are kept strictly confidential.

Employees can choose to go through their direct or dotted-line supervisor, the designated officer in their entity, or a local platform for reporting concerns. Employees can also contact the Chief Ethics and Vigilance Officer at Group level directly or use VINCI Integrity, the Group’s whistleblowing platform.

External stakeholders can also access VINCI Integrity from the Group’s website to report concerns.

These reporting channels ensure that information is transmitted in a reliable, highly secure manner, with end-to-end traceability.