2024 Universal Registration Document

General and financial elements

4. Duty of vigilance with regard to the environment

VINCI’s environmental issues are managed at the highest level of responsibility by the Strategy and CSR Committee of VINCI’s Board of Directors, which ensures that they are integrated into the Group’s strategy (see paragraph 1.2.1, “ESG governance”, of the Sustainability report, page 191). In 2019, awareness of the climate emergency and the environment became more acute, leading to the definition of a new environmental ambition involving all VINCI entities for the 2020-2030 period. It targets three areas, aligning with the key challenges faced by the Group’s businesses: climate change, the circular economy and the preservation of natural environments. The Environment Department coordinates the ambition across the Group’s entities and each year it reports twice to the Executive Committee and three times to the European Works Council. It chairs monthly meetings of the Environmental Committee, whose members are the environmental managers and directors of the Group’s business lines, and coordinates the network of more than 800 environment officers.

On 6 November 2020, Xavier Huillard, Chairman and Chief Executive Officer of VINCI, and Roberto Migliardi, Secretary of VINCI’s European Works Council, signed VINCI’s Environmental Guidelines (www.vinci.com/publi/manifeste/dir-env-2020-11-en.pdf). This document provides a framework for reducing environmental impacts and risks associated with the Group’s activities. It applies to all Group companies and each subsidiary is responsible for ensuring that appropriate actions are also taken by subcontractors and joint contractors throughout projects.

The Group’s Environment Department shapes the environmental component of the duty of vigilance plan, based on the environmental goals shared by VINCI’s business lines and entities for the three targeted areas. VINCI’s environmental ambition extends the environmental actions of VINCI companies beyond compliance with the regulatory requirements of the countries in which they operate.

Measures to identify and prevent environmental risks are largely influenced by the geographical locations of companies and their activities as well as the vulnerability of the surrounding areas. The Group’s environmental policy is translated into operational guidelines in each of its business lines, which then establish a road map taking into account the specific nature of their activities and regions, with the aim to drive continuous improvement. In subsidiaries, chief executives and senior management are in charge of ensuring regulatory compliance and the implementation of risk prevention procedures in their operational scope, taking into account their specific activities and challenges. They are assisted by the network of environment officers who provide environmental expertise (see paragraph 1.3, “ESG risk management and internal control”, of the Sustainability report, page 192).

4.1 Mapping of the Group’s major environmental risks

In accordance with the EU’s Corporate Sustainability Reporting Directive (CSRD), VINCI conducted a double materiality assessment in 2024 to map its environmental risks. The assessment process is described in detail in paragraph 1.1.2, “Double materiality assessment”, of the Sustainability report, page 188. The material impacts, risks and opportunities that were identified through the process are presented in section 2 of the Sustainability report, focusing on the environment.

4.2 Assessing the situation of subsidiaries, subcontractors and suppliers
4.2.1 Assessing the situation of subsidiaries and subcontractors

Multiple environmental assessment processes are in place in the Group to fulfil regulatory requirements, meet stakeholder expectations and comply with internal company policies. The very first principle laid out in the aforementioned Environmental Guidelines refers to identifying and assessing risk.

Environmental certification

Most Group entities assess their performance by implementing an effective environmental management system and obtaining ISO 14001 certification. Environmental management systems guarantee a robust level of risk prevention and management through annual external audits. The percentage of the Group’s activity covered by ISO 14001 certification is calculated in relation to revenue or another relevant indicator, depending on the business line. ISO 14001 certification covered 67% of VINCI’s revenue in 2024 (see paragraph 1.3.2, “ESG risk management and internal control, of the Sustainability report, page 192).

Third-party controls

The activity of the Group and its subcontractors is also regularly reviewed by other external bodies:

  • government agencies carry out inspections to ensure compliance with regulations on worksites;
  • customers and programme managers mandate design offices to conduct environmental audits of worksites on a regular basis, to monitor compliance with the Group’s regulatory and contractual obligations;
  • nearby residents and local civil society organisations increasingly scrutinise construction and quarry sites, especially when a consultation process has been established that enables partner organisations to visit the site and verify that the commitments made are being fulfilled;
  • financial institutions and international financing providers sometimes take special measures to monitor projects with a high risk of environmental impact;
  • more specifically, independent design offices perform audits on worksites to check compliance of waste storage, processing and disposal procedures.

When any non-compliance is identified through these audits or monitoring processes, the onus is on the companies responsible to explain the shortcomings and promptly correct them.

Internal control

The Group’s Executive Committee and Board of Directors examine and approve material ESG impacts, risks and opportunities each year, relying in particular on the work of the Audit Committee (see paragraph 1.3.2, “ESG risk management and internal control”, of the Sustainability report, page 192). Given VINCI’s decentralised organisation, the Environment Department ensures that the Group’s environmental rules and procedures are applied by business lines and provides them with technical assistance, while respecting their freedom over operational decisions. In business lines and divisions, environmental correspondents regularly carry out inspections and audits of internal as well as subcontractors’ operations. Group companies measure the environmental footprint of their projects and activities and report on the internal and external resources implemented to protect the environment.