2024 Universal Registration Document

General and financial elements

The increased number of assessments has encouraged subsidiaries to share practices and experience among themselves. Audit recommendations are constructive and practical, so they can be effectively applied in the subsidiary’s operations. For example, a subsidiary may be advised to incorporate social risk prevention into the checklists used by their managers for site inspections or into the mobile applications that have already been developed for health and safety visits, rather than create new tools.

3.7 Reinforced vigilance to fight forced labour and illegal work (*)

Preventing risks of forced labour

he Group has long been committed to the fight against forced labour. Because forced labour is such a serious risk, VINCI is particularly aware that special scrutiny must be paid to the conditions in which migrant workers are recruited and employed, whether directly or indirectly, via temporary employment agencies or subcontractor companies.

The underlying factors driving forced labour can vary from region to region. VINCI considers that this issue must be handled close to where the problem occurs in order to take effective actions that suit the on-the-ground realities. The risk of forced labour can come from certain legislative frameworks that do not align with international conventions or arise from unfair local practices, which are sometimes deeply embedded. Many problems arise early in the recruitment phase, even before workers arrive at the project site or are hired by the Group.

The risk generally intensifies when an activity depends on a high volume of low-skilled workers or where labour migration flows are significant. Some workers seek to migrate to another country for higher wages or due to economic or geopolitical instability, and the construction sector offers attractive job opportunities. Although VINCI promotes local sourcing of labour, Group companies may recruit migrant workers to meet their business needs in certain regions, mainly due to local labour shortages. Once workers migrate for work, they become dependent on their employer not only for their employment but also with regard to their living conditions and accommodation. They are more vulnerable than other workers and face a greater risk of exploitation. This risk is amplified if they do not speak the language of the host country, are unfamiliar with cultural norms or have a limited understanding of their rights.

For many years, VINCI has been developing and adapting approaches and operational tools to combat forced labour. To achieve this goal, VINCI works with its internal stakeholders as well as a range of other collaborators offering complementary expertise. Likewise, in addition to reinforcing policies and internal practices within the Group, VINCI shares its experience and engages with many different stakeholders to improve the industry’s practices as a whole.

In order to provide its teams with operational guidelines, the Group identified concrete risks related to forced labour: the risk of recruitment fees and debt, the risk of employment contract substitution, and the risk of confiscation of workers’ working permits, identity documents, visas and passports. The guidelines also cover risks relating to working conditions (wages, working hours, etc.), accommodation and value chain practices. All the tools developed to implement the Group’s human rights policy, ranging from risk maps to assessment scorecards (see the above paragraphs), address these risk factors.

Responsible recruitment is an area of priority in VINCI’s approach to protecting human rights. The Group has identified two higher-risk regions – the Gulf countries and South-East Asia – in which it is concentrating its initiatives. These include developing courses to train managers to detect and prevent forced labour risks, especially through practical case studies. In 2024, VINCI’s Social Responsibility Department held several responsible recruitment awareness and training workshops in the Gulf region. It continues to teach operational teams various ways to prevent risks, providing practical tools and approaches that can be used with supply chain partners as of the selection phase, while drafting contract clauses and auditing subcontractors and recruitment agencies.

VINCI also keeps a close eye on any new tools developed by human rights organisations. Some Group companies use the Cumulus platform for several operations. It was designed by the NGO Verité to audit practices in supply chains, especially those of recruitment and temporary employment agencies. Building on its experience in Qatar, the Group works with teams in the United Arab Emirates, Bahrain and Saudi Arabia to prevent risks facing migrant workers. Human rights assessments were conducted to take appropriate preventive and corrective actions adapted to the situation in each country. In the United Arab Emirates, Building and Wood Workers’ International (BWI) visited the 2F1 railway depot project to gain insight into existing practices.

VINCI’s approach draws on the initiatives and the measures that were taken at QDVC (see following paragraph, “Risk prevention in Qatar”, page 295) and from the public-private partnership with the ILO Project Office in Qatar from 2018 to 2021, which sought to create a migration corridor between Qatar and Bangladesh, with no recruitment fees for workers. Following an initial audit by the NGO Verité, a complete capacity-building programme was rolled out for recruitment and placement agencies in Qatar and in home countries. Follow-up meetings to provide support were held in Doha and Dhaka. An independent assessment was conducted to assess the impact of ethical recruitment on the workers and their employers. It was based on interviews with workers at various stages of the recruitment process and during their employment. The findings of the pilot project were published at the end of 2021(**) presented to a number of universities and communities of experts, as well as civil society organisations. One of the conclusions was that the capacity-building workshops had resulted in an immediate and profound improvement of placement agency practices. Placement agencies had improved the drafting and terms of contracts with recruitment agencies in home countries and followed the use of subagents more closely, in particular by providing a transparent breakdown of costs.