2024 Universal Registration Document

General and financial elements

This methodology was applied for five priority purchasing categories, in collaboration with VINCI Energies in France, VINCI Construction in France and VINCI Energies International & Systems. Specific action plans were developed and are being rolled out by the relevant business lines and divisions.

VINCI has also developed a general social, environmental and ethics assessment questionnaire, which has been used for several years by various business lines to review the CSR performance of suppliers when selecting them or at any time during the contractual phase. For the categories with the highest risk exposure, the Group has drawn up more than 20 specific human rights and environmental assessment questionnaires tailored to the sectors or industries concerned, to be used in connection with calls for tenders.

For the priority purchasing categories, as part of a continuous improvement approach and to support suppliers with the highest social and environmental risk exposure, on-site audits are planned and conducted directly by VINCI and the business lines. While prioritising Tier 1 suppliers, these audits can also be extended to Tier 2 and beyond, depending on the level at which the most significant social and environmental risks have been identified. During the last quarter of 2024, the Group developed an audit scorecard that can be adapted in line with the priority issues to be audited. Working with VINCI Construction’s Road France and Networks France divisions, this scorecard was tested on suppliers from a single sector ranging from Tier 1 to Tier 5. It will be deployed across all business lines in 2025. Human rights and health and safety audits are carried out for VINCI subcontractors working on the Group’s projects, as presented in more detail in paragraphs 2.6, “Assessing the situation of subsidiaries, subcontractors and suppliers”, page 285, and 3.4, “Assessing the situation of subsidiaries, subcontractors and suppliers”, page 290, both in chapter F, “Duty of vigilance plan”. Following each audit, a progress plan is drawn up and its implementation is monitored over time by the assessors.

Training for employees handling purchases

Developing the level of knowledge and training all employees handling purchases to systematically take into account sustainability aspects is vital to the successful implementation of VINCI’s responsible purchasing approach. The Group is therefore putting in place different approaches to further strengthen responsible purchasing skill levels and provide each entity with ad hoc tools to implement a responsible purchasing approach.

An initial phase to raise awareness was carried out through a responsible purchasing e-learning module to help employees absorb the content of the Group’s practical guide on responsible purchasing. Available in five languages, this module is designed for all employees, across all business lines, and was completed by nearly 2,400 employees in 2024, taking the total figure since its launch at the end of 2022 to over 6,000.

A more in-depth course for the purchasing teams has also been in place since 2021, covering employees in key positions for the Group’s purchases. Due to the growing demand for sustainability skills development and to ensure that this advanced course remains relevant, its content was updated in 2024 and continues to be distributed across the Group’s business lines in France and around the world. To meet more specific needs and cover as many employees as possible, the Group is also working with the divisions to develop training programmes with formats and contents that are better suited to the various roles, and particularly the legal, human resources, health and safety, and QHSE teams.

Focus on the management of social risks in subcontracting and on-site services

Very early on in its human rights approach, subcontracting and on-site services were identified as priority purchasing categories within the Group’s vigilance approach. Along with temporary employment agencies, these three categories account for half of the Group’s total purchases and are strategic for VINCI. While subcontracting and temporary employment companies, which are often directly involved alongside Group companies at its worksites and operating sites, are already subject to extensive checks, they are considered to be intrinsically exposed to social risks.

In a first phase, the Group provided all of its 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.

At the same time, a specific approach for managing social risks in subcontracting was launched in France. It tested the due diligence methodology and enabled the tools to be adapted to the Group’s organisation and business sectors. In addition to supporting the subsidiaries concerned, this initiative paved the way for a social component to be included in a subcontractor approval tool and the development of a methodology and scorecard for social audits of subcontractors and providers, tailored to the Group’s business activities. These audits cover a range of factors, including working conditions (recruitment conditions, working hours, remuneration, etc.) and compliance with health and safety rules, such as wearing personal protective equipment (PPE).

In addition, an in-house training programme has been developed on how to conduct social audits of subcontractors and worker interviews, primarily for the human resources, social affairs and legal teams. To date, more than 200 in-house auditors in France have completed this training. The next step, which is already under way, involves supporting subsidiaries outside France as they implement these same measures. For further details, see under “Preventing social risks and illegal work in subcontracting” in paragraph 3.7, “Reinforced vigilance to fight forced labour and illegal work”, of chapter F, “Duty of vigilance plan”, page 297.

When assessing performance by subsidiaries in terms of managing human rights risks, particularly in the Group’s operations outside France, part of the assessment looks at the extent to which subsidiaries are aware of the working and employment conditions of subcontractor employees (and temporary workers) who work alongside them. The ways in which they manage social risks among subcontractors and temporary employment agencies when using their services are also assessed. These assessments are often accompanied by interviews with both workers and representatives from the subcontractors or providers. When required, action plans are drawn up based on the findings from these assessments.

In 2025, VINCI will roll out a toolkit including assessment questionnaires, sample criteria, a guide for drafting specific clauses adapted to the risks identified and the types of services, standard clauses and a social audit scorecard for subcontracting, as well as a semi-automated social and environmental risk mapping support tool. Considering the Group’s decentralised organisation and the specific features of each business, their implementation will be led by each business line and each company.

Combating forced labour

Lastly, VINCI has long been committed to the fight against forced labour. Various actions are carried out, as presented in detail in paragraph 3.7, “Reinforced vigilance to fight forced labour and illegal work”, of chapter F, “Duty of vigilance plan”, page 294.