These programmes ensure that employees understand the related domestic and even international legal frameworks, and are able to identify the issues and responsibilities involved. They explain the corruption scenarios identified and the risks involved, the steps to be taken to reduce these risks, the recommended behaviours when faced with solicitations and the procedures for reporting inappropriate conduct, as well as the disciplinary actions that may be taken or the criminal penalties that may apply to individuals for any infringement of rules or regulations. As exemplary managerial behaviour is essential to effectively spearhead ethical practices within its subsidiaries, the Group’s conduct guidelines are covered in all of the management training programmes provided by the academies.
| Total anti-corruption training courses(*) | Group “Anti-corruption” e-learning module (A) |
Group “Conflicts of Interest” e-learning module (B) | Anti-corruption training courses other than Group e-learning modules (A) and (B) | |||
|---|---|---|---|---|---|---|
| Number of people trained | Number of hours of training | Number of people trained | Number of people trained | Number of people trained | Number of hours of training | |
| Number of active employees who have taken the training (**) | 97,000 | 133,000 | 97,000 | 82,000 | 23,000 | 85,000 |
| Number of active employees who took the training in 2024 | 42,000 | 55,000 | 19,000 | 42,000 | 11,000 | 41,000 |
| Average length of training | Variable (from 10 minutes within a training session on other topics including anti-corruption to six hours focusing on the subject) | 20 | 12 | Variable (from 10 minutes within a training session on other topics including anti-corruption to six hours focusing on the subject) | ||
| Frequency | Variable (from “at least once since hire” to “every year”) | At least once since hire / unlimited availability | At least once since hire / unlimited availability | Variable (from “at least once since hire” to “every year”) | ||
| Training format (in-person, interactive videoconference, e-learning, mobile learning, etc.) | E-learning, hybrid (in-person and videoconference), webinar | E-learning | E-learning | E-learning, hybrid (in-person and videoconference), webinar | ||
| Targeted at-risk positions | All VINCI Group managers and all employees exposed to risks of corruption and influence-peddling. This involves, at a minimum:employees involved in negotiating purchases of any kind of supplies or services
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Whistleblowing reporting and processing procedures. One of the key measures for detecting potential corruption is to implement whistleblowing reporting and processing procedures, as described in paragraph 4.2.3, “Identification and detection of risks”, page 270.
Anti-corruption controls. The Group’s accounting processes, which include anti-corruption accounting controls, contribute to detecting cases of corruption. Second-level controls are implemented to check the application and effectiveness of anti-corruption measures. Finally, the internal audit plans and self-assessment processes, overseen by the finance teams, include a series of questions aimed specifically at ensuring that anti-corruption systems do exist and are efficient.
(c) Remediation measures
The Anti-corruption Code of Conduct stipulates that any violation of applicable anti-corruption laws and regulations and any violation of the code can lead to disciplinary action. The law stipulates appropriate sanctions and proceedings that apply to the employee concerned.
During the reference period, one Group subsidiary appeared in court after a guilty plea to charges of breaching anti-corruption law and accepted the penalty proposed by the prosecutor of a €1 million fine.
The company immediately reacted and took the following remediation measures:
In line with the Group’s decentralised structure, each subsidiary carries out a proportionate review (type of purchases planned, identified risks, company size) and selects its purchasing partners based on their ability to honour the commitments expected by the Group, as stipulated in the All-round Performance Charter for Purchasing Partners. The Group’s policy in this area is described in paragraph 3.2.2.1, “Human rights and health and safety issues for purchasing and subcontracting”, page 256.
