The Human Rights Steering Committee monitors implementation of the road map and discusses it with the Strategy and CSR Committee of the Board of Directors.
The Group’s business lines and divisions continue to use indicators to track the advancement of human rights assessments and report on progress to their management. For example, VINCI Construction Grands Projets has developed a set of indicators that it monitors and presents monthly to the management committee. The indicators provide information on assessments performed, follow-up, progress, and the resolution of non-compliance. Similarly, VINCI Energies International & Systems systematically monitors its assessments and action plans and makes regular reports on results to its management.
In some cases, the Group arranges for independent audits or other external controls to manage major risks. This was the case in Qatar, where VINCI, its subsidiary Qatari Diar VINCI Construction (QDVC), and Building and Wood Workers’ International (BWI) signed a framework agreement, (*) which set up an audit and control system overseen by a group of representatives of the three parties. The agreement addresses human rights in the workplace, accommodation, and issues relating to the fair recruitment and the labour rights of workers. It applies to all workers employed by QDVC in Qatar, including subcontractors’ employees and temporary workers. The last compliance audit was performed with all parties present. VINCI’s trade union representatives were also invited to participate. It covered all items in the agreement, and the audit results were made public. QDVC completed its last major worksite in 2024 and has significantly reduced its workforce as a result. The signatories mutually agreed that no further audit was necessary.
Especially in the context of a major project, the Group sometimes employs independent service providers to assist teams in assessing human rights risks and designing impact mitigation early on, for example, during bidding or the preparation phase once a contract has been awarded.
Integration of human rights into the Group’s internal controls
VINCI’s internal control system has been expanding its focus to increasingly include human rights. In addition to reinforcing risk committee reviews of environmental and social risks, and as a complement to the controls performed by business lines and divisions, the Group may initiate unannounced verifications of compliance with the rules set out in its reference documents. The audits led by VINCI’s internal control team may include customised questions relating to human rights issues, developed in collaboration with the Social Responsibility Department. In 2024, five of the audits conducted by the Internal Audit Department included an evaluation of human rights risk prevention, attended by the Social Responsibility Department. In addition, following a first joint human rights assessment in 2023, a representative of the Internal Audit Department took part in several other assessments led by the Social Responsibility Department in 2024. Further joint audits will be carried out in 2025.
Seven years ago, VINCI added a section on preventing human rights risks to its annual internal control survey. The survey aligns with the requirements of the reference framework published by the Autorité des Marchés Financiers (AMF, the French securities regulator), which states that parent companies must ensure that subsidiaries have risk management and internal control systems. In 2024, the questions covered topics such as the dissemination of VINCI’s Guide on Human Rights and participation in the human rights risk awareness e-learning course across the Group, but also collected data on employees’ working hours, subsidiaries’ verification of the working conditions of temporary workers and subcontractors’ employees, and the availability of a whistleblowing system. Survey findings are presented to the heads of internal control, the members of the Human Rights Steering Committee and the members of the Board of Directors and shared with the business lines and divisions. The Group also uses the survey results to adapt or reinforce certain initiatives.
Group monitoring of risk prevention and mitigation
In addition to carrying out new and follow-up human rights audits during the year, the Group monitors the progress of action plans, especially those in place within entities in high-priority countries. Follow-up assessments are usually scheduled within the six months following an audit. Documenting processes, taking steps to reduce social risks in subcontracting, and expanding whistleblowing procedures are the main areas frequently identified as needing improvement.
Measures to audit subcontractors’ employment practices have been gradually reinforced. Several assessments prompted subsidiaries to update their action plans with items such as revising contract templates to include new clauses to manage social risks. These clauses hold subcontractors to a higher standard than local labour law and/or apply requirements to a wider range of partners. These action plans also generally seek to develop and implement measures to verify compliance with employment-related criteria, in particular for the categories of subcontractors or service providers that present the highest risk. Examples of measures include social audits at subcontractors and service providers and better integration of human rights considerations into the various stages of contract management. At some worksites, such as in Colombia, an initial human rights assessment was followed up with the implementation of systematic, daily verifications of each worker’s employment contract or work permit as they enter the worksite. Subcontractors operating at worksites are closely monitored. Compliance with contractual commitments to uphold the project’s human rights standards is verified weekly.
Assessed subsidiaries were also encouraged to improve their whistleblowing procedures in various ways, such as by raising worker awareness of the whistleblowing system, applying it more explicitly to human rights concerns, opening it up to subcontractors and service providers working on a site, and making its rules of use more transparent. Assessments sometimes led subsidiaries to enrich their employee surveys with questions about working conditions.
In subsidiaries where employers are responsible for workers’ accommodation, checklists were rolled out to ensure regular and consistent verifications of the living conditions of workers, including those of subcontractors. Company managers also conduct on-site inspections of workers’ accommodation.
