Risk assessment ahead of new projects or company acquisitions
While rolling out the Managing Human Rights assessment platform, the Group also worked to bolster its teams’ ability to identify and address issues before the start of a project, during bid preparation – especially for large projects. In 2023, the risk scorecard used by the Construction and Energy businesses and the accompanying explanatory note were reviewed and validated in coordination with the Audit and Internal Control Department and with the input of the Environment Department and the Ethics and Vigilance Department. The scorecard and note are among the documents that must be presented to the VINCI Risk Committee for approval before submitting a bid to the client, if certain thresholds are reached. They now include an expanded section focusing on social and environmental risks, alongside technical and financial risks. For example, the human rights risks items cover the management of impacts on local communities and nearby residents and the rights of direct and indirect employees.
In addition to the scorecard to be presented to the VINCI Risk Committee, the Group developed an environmental and social questionnaire with 44 items, along with guidance explaining various aspects to be considered. It was designed to help the teams in charge of bids to identify the risks and issues that could impact a project (due to the local or operational context or the type of services to be provided). They can then anticipate the necessary measures and take them into account, either by adjusting the project’s resources and means or by redefining the services to be provided. In 2024, the questionnaire was translated from French into English and Spanish. It is already in use by some teams. Training sessions will continue to be rolled out, targeting people in charge of responding to calls for tenders in the Group’s entities.
A similar approach was taken in 2021 for acquisitions. Prior to new acquisitions, a risk assessment must be conducted to examine such aspects as the country of operation, the company’s commitments and the resources devoted to preventing human rights risks. This information is reviewed by risk committees whenever certain thresholds defined by the Group are met.
Assessing the situation of subcontractors and suppliers
In VINCI’s businesses, whether in concessions, energy or construction activities, the major challenges arise at operational level. Accordingly, when it comes to vigilance with regard to human rights risks in the value chain, priority is given to subcontractors, service providers and temporary workers employed at worksites and operating sites.
The Group has provided all 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. Likewise, subsidiaries can use the Managing Human Rights platform to assess their knowledge of the working and employment conditions applied by the subcontractors and temporary employment agencies with which they collaborate. The tool also enables them to evaluate how they manage social risks in subcontracting and temporary employment. Verifications and audits are carried out on a case-by-case basis. To help business lines and divisions implement the methodology, the Group has launched various initiatives. For example, in 2023 and in 2024 it appointed a multidisciplinary task force – bringing together operational team members and representatives from the purchasing, human resources, finance, social affairs and risk prevention departments of business lines and divisions – to develop a toolkit to strengthen the prevention of social risks in subcontracting (see paragraph 3.7, “Reinforced vigilance to fight forced labour and illegal work”, page 294).
In respect of temporary employment agencies (TEAs), the Group’s Purchasing Coordination unit has set up a framework agreement to select approved agencies, which must be used by VINCI’s companies in France. During the latest renewal process in 2023, all of the assessed TEAs answered a mandatory sustainability questionnaire with six separate sections: recruitment and employment conditions, occupational health and safety, non-discrimination, training and skills development, prevention of illegal or undeclared work, and the availability of a whistleblowing system. Audits of 14 of the agencies were carried out, either because their questionnaire results were slightly unsatisfactory or because alerts were received by the Purchasing Coordination unit. In all, 43 of the 144 assessed TEAs were excluded on the basis of ESG criteria or audits. A new contract for 2023 to 2025 was signed with 89 TEAs and an ESG improvement action plan was established for 24 of them. The Group’s Purchasing Coordination unit monitors these action plans (see section 2, “Duty of vigilance with regard to health and safety”, page 280). Group companies also implement controls after the selection phase, during the performance of contracts with agencies, to prevent risks of infringing workers’ rights. For example, payroll systems are checked to ensure that all hours worked are being paid and that the required social contributions and declarations are being made to the relevant organisations, to ensure that workers access the social benefits to which they are entitled. These items are also verified when subsidiary assessments are performed using Managing Human Rights.
Regarding other suppliers, see see paragraph 3.2, “Human rights and health and safety within the value chain (ESRS S2)”, of the Sustainability report, page 256.
