4.3 Prevention and detection of corruption and bribery – Cases of corruption or bribery
Le Groupe a mis en place un dispositif anticorruption robuste constitué de mesures visant à identifier et gérer les risques de corruption et de trafic d’influence.
COMMITMENT OF EXECUTIVE BODIES
ANTI-CORRUPTION CODE OF CONDUCT
RISK MAPS
INFORMATION AND TRAINING
THIRD-PARTY ASSESSMENT
ANTI-CORRUPTION ACCOUNTING CONTROLS
INTERNAL AUDIT CONTROLS
WHISTLEBLOWING REPORTING PROCEDURE
In line with the Group’s decentralised governance structure, VINCI’s Executive Management stipulates in its general guidelines that operational members of the Executive Committee are required to implement measures adapted to their respective business sectors for detecting potential acts of corruption and influence peddling.
4.3.1 Identification and assessment of corruption risks
The Group regularly conducts mapping exercises to identify and assess corruption risks. Led at the most appropriate levels of the organisation, mapping is a collaborative process that takes into account the specific context of the business and the country. These maps are used to prioritise identified risks and define adapted action plans to improve risk management. The aim is to maintain complete coverage of the Group’s activities.
4.3.2 Management of corruption risks
To manage corruption risks, the Group deploys:
- prevention measures, including the dissemination of the Anti-corruption Code of Conduct, anti-corruption training and assessments of the integrity of third parties;
- detection measures, including the use of internal whistleblowing reporting and processing systems and specific anti-corruption controls;
- remediation measures, including the application of disciplinary actions for any violation of the Anti-corruption Code of Conduct, as well as corrective measures.
The Group is engaged in a continuous improvement approach relating to its risk management systems, which involves regular updates and reinforcement of the measures in place.
(a) Prevention measures
Dissemination and acceptance of the Code of Ethics and Conduct and the Anti-corruption Code of Conduct. All Group employees and all its stakeholders have access to the Code of Ethics and Conduct and the Anti-corruption Code of Conduct, which are available on the Group’s website.
The Group has also issued a recommendation and implemented an IT tool to structure the dissemination of the Code of Ethics and Conduct and the Anti-corruption Code of Conduct to targeted employees and their acceptance of these codes. The Group’s recommendation is to distribute these two documents to the main responsible parties, comprising at a minimum senior executives, operational and functional executives, and specific managers including those responsible for specific agencies and activities, projects, purchasing, human resources, accounting and finance. However, each business line remains free to identify a wider target group for the dissemination and acceptance of the codes. At 31 December 2024, more than 80,000 active employees had electronically signed and accepted the Code of Ethics and Conduct and the Anti-corruption Code of Conduct.
Assessment of the integrity of third parties. The Group has issued a recommendation for business units to define and implement procedures that assess the integrity of third parties. In line with the corruption risk map, this process takes place at the most appropriate levels of the organisation.
Employee training. Training and information are key factors for implementing the Group’s business ethics policy. To enable all employees to effectively contribute to preventing and detecting corruption, depending on their duties and responsibilities, specific training programmes are developed and rolled out at each of the Group’s organisational levels. These modules complement the general e-learning training courses on the Group platform, such as the “Anti-corruption – Challenges and Risks” and “Conflicts of Interest” courses.