2024 Universal Registration Document

An e-learning course to raise human rights risk awareness is available to all entities and employees in nine languages (English, French, Spanish, Portuguese, Polish, Czech, Italian, German and Romanian). These nine languages are understood by more than 90% of workers, based on the official languages of the Group’s countries of operation. Additional translations are in progress and will become available in 2025. The course, which is specifically adapted to VINCI’s business lines and results from a year of collaborative in-house development, has been designed as a role-play exercise. It primarily addresses managers of entities, projects or worksites, as well as those in charge of human resources, administration, finance, and health and safety. Completion is monitored and reported to the Human Rights Steering Committee. At the end of 2024, more than 45,000 employees in 110 different countries had finished the course (30,000 employees in 103 countries at the end of 2023).

An additional course has also been developed for managers of concessions to provide an interactive presentation of the issues that may arise during a project’s three phases: development, design and construction, and operation and maintenance. By the end of 2024, more than 2,600 concessions employees had completed the course, which is available in six languages. Lastly, several of the Group’s well-established, emblematic training programmes now include a human rights component. One example is Team Grands Projets, a training course shared by all VINCI Construction divisions, designed to build the skills of managers of major projects and help them handle complex environments more effectively. The Cooperate programme is another example. Both use role-play exercises based on situations from internal or external case studies.

Whistleblowing systems for raising concerns ^(*)

The Group also upholds its commitments by providing multiple channels through which its employees and stakeholders can report concerns. These channels include contacting human resources departments, health and safety representatives, line managers or employee representative bodies. If confidentiality is an issue, employees can also approach the ethics officers of the Group’s business lines and divisions or at Group level.

In addition to the whistleblowing system at Group level (see section 5, “The Group’s whistleblowing system”, page 303), VINCI’s multi-local organisation and the nature of its activities leads the Group to encourage the implementation of local procedures for reporting concerns. The Group’s view is that whistleblowing systems and alert procedures that are local and open to reports by temporary workers, indirect staff, end users or local residents ensure that the company, project or worksite is better positioned to proactively handle reports, implement appropriate corrective measures, identify any weak areas in the organisation and reinforce its preventive measures.

A number of Group companies have set up additional methods, other than alerting the line manager, to report complaints or situations that present a risk, such as a human rights risk. Such methods may consist of procedures providing access to a dedicated email address, hotline or digital solution. Some companies, such as LISEA in France and Lima Expresa in Peru, have a contact point for the public on their websites. Others outsource the processing of reports to an independent body. This is the case for Seymour Whyte in Australia, VINCI Construction in the Czech Republic and Slovakia, and Vía Sumapaz in Colombia. In the Gulf region and Africa, specially trained corporate social responsibility coordinators or occupational social workers are in charge of receiving any complaints from workers, whether directly or indirectly employed, and members of the local community. They also maintain a log and ensure that the problems raised are quickly resolved.

Although VINCI entities are sometimes the customer, their role is very often that of subcontractor or service provider. In these situations, Group entities are encouraged to participate in the processes put in place by their customers. This is the case for Sogea-Satom projects. Their motto is that a worksite with no complaints is a worksite with no procedure to monitor them. In addition to enabling teams to report concerns using customers’ existing systems, they maintain complaint logs and hold public meetings. Complaints and their handling are monitored using a small number of simple indicators: number of complaints, corrective action taken and its effectiveness (whether the issue recurs), and resolution time. The company produces a report and notifies the customer of any problems that could not be resolved.

These whistleblowing systems and the examination of the concerns that are raised also contribute to the identification and analysis of areas where VINCI must be vigilant.

3.4 Assessing the situation of subsidiaries, subcontractors and suppliers (**)

Managing Human Rights, a tool to assess subsidiary practices

The Managing Human Rights platform developed by VINCI is used to evaluate whether the management systems implemented by subsidiaries conform to the Group’s guidelines and whether they specifically address and prevent the risks identified in a given country, in the subsidiary’s own operations and in its relations with subcontractors and temporary employment agencies. The entity or project then reports on the results and improvement plan to its division’s Human Resources Department, which in turn informs the Group through its steering committee representative. As necessary, major risks are monitored at Group level. The assessments are carried out by the Social Responsibility Department or by specially trained staff in business lines and divisions, and comprise some 200 questions.

For example: Has the company checked that the workers did not have to pay a recruitment fee? Has it checked that the hours worked by temporary workers and subcontractors’ employees on its sites are accurately recorded and that social contributions are fully paid? Has it ensured that there are systems in place to inform and consult local residents and communities that could be impacted by projects? The questions are precise, concrete, and relate to the five salient human rights issues and 17 themes (see paragraph 3.1, “Major risk identification and analysis”, page 287). The four response options range from “no practices” (Level 1) to “best practices” (Level 4). In most cases, an assessment is carried out over several days and involves collaborative group sessions bringing together operational managers and members of the management committee of the entity or project. Visits are also made to examine sites and worker accommodation, and interviews may be conducted with employees, temporary workers and/or subcontractors and their employees. The assessment therefore involves all the management teams of an entity or a project, together with its human resources, health and safety, finance, legal, purchasing and other support functions, for several days. After completing the assessment, the entity or project receives an evaluation of its practices, along with recommendations, and can build an effective action plan. Not only do these assessments deliver a very operational view of the Group’s human rights principles, they also promote the spread of best practices. Additionally, they provide opportunities to share the many tools that already exist – for recruiting ethically, eliminating discrimination, implementing a whistleblowing procedure, providing a living wage, managing social risks in subcontracting, and so on – to enhance human rights risk prevention and mitigation. The Managing Human Rights platform is an essential component of VINCI’s efforts to promote human rights. It has been made available in English, French and Spanish on the Group’s intranet, vinci.net, so that VINCI’s nearly 285,000 employees can become aware of and engage with human rights issues. At the end of 2024, 138 subsidiaries and projects in 44 countries had been assessed using the platform (see paragraph 3.6, “Monitoring implementation and effectiveness”, page 292).