2025 Universal Registration Document

1.3.2 Fraud

Fraud
Risk identification	Risk management procedures
Risk identification Fraud: intentional act by an employee or a third party aimed at embezzling Group assets assets. The systems of a group as decentralised and diversified as VINCI are exposed to the risk of both internal and external fraud, especially as regards payment systems. Attempts at fraud generally target the individuals involved in external payment processes. Possible consequences: Financial loss Blackmail Damage to the Group’s reputation	Risk management procedures External fraud prevention involves several Finance Department, Security Department and Information Systems Department units. The core system includes reporting by way of an online platform (accessible via a link on VINCI’s intranet), enabling central services to react immediately and facilitating analysis of fraud attempts. The fraud prevention instructions available on the Group’s intranet specify correct conduct in the event fraud is suspected, guidelines concerning means of payment and awareness-raising measures to be taken in regard to the key personnel faced with this kind of situation. Specific information and recommendations are regularly distributed to CFOs and anti-fraud coordinators. Internal fraud prevention is based on VINCI’s Code of Ethics and Conduct as well as on specific training or awareness initiatives. It is described in section 4, “Business conduct”, of chapter E, “Sustainability report”, pages 283 to 288. The procedure entitled “Preventing and combating fraud at VINCI SA” published on the Group’s intranet covers internal and external fraud and lists the Group personnel involved in combating fraud. It also provides an overview of all systems implemented to prevent and combat fraud effectively.

1.4 Social risks

The Group’s social risks are set out in full in section 3, “Social ambition”, of chapter E, “Sustainability report”, page 246, and in chapter F, “Duty of vigilance plan”, beginning on page 295. The information provided in these sections includes both the impact that VINCI’s activities can have on society and, vice versa, the potential effects of social issues on the Group.

Group companies are subject to risks related to the working conditions of their employees. They must also deal with the significant impact they have on stakeholders and communities in the regions where they are active. These social risks are taken into account at every project stage and are analysed far upstream so as to identify local issues and the expectations of stakeholders, including employees and their representatives. Appropriate measures are implemented as a result of this analysis. Similar analyses are carried out regularly throughout the life of each project.

In addition, a detailed assessment of impacts, risks and opportunities (IROs) related to social issues was carried out in preparation for the Group’s sustainability report, following the double materiality principle (see section 3, “Social ambition”, of chapter E, pages 245 to 282). The approach applied for sustainability reporting, which identifies and assesses the potential risks and gross impacts of VINCI’s activities without taking account of the risk management measures in place, differs from the analysis presented in this chapter, which assesses the residual risks that may be faced by the Group.

1.4.1 Human rights

VINCI companies have strong roots in the regions where they operate; these areas have very different labour standards. The companies must also meet international standards of human rights: the UN Global Compact, which VINCI signed in 2003; the UN Guiding Principles on Business and Human Rights; and the International Labour Organisation’s fundamental conventions.

Group companies ensure that they uphold human rights in their operations and place great importance on their employees’ working conditions, on those of their subcontractors and service providers, and on respect for local communities. They remain exposed to allegations brought or controversies raised by human rights organisations and other NGOs, local communities and residents, international organisations and institutions, or financial institutions. These can affect the Group’s image.

Human rights
Risk identification	Risk management procedures
Risks inherent to the nature of construction activities: labour-intensive, cyclical character and multiplicity of participants in the value chain (subcontractors, service providers and temporary staff) Lack of staff training and/or clear guidelines, non-compliance with Group rules Expropriation of local populations by public stakeholders Possible consequences: Deterioration in relationships with stakeholders Legal proceedings and potential conflicts with employee representative bodies, human rights organisations and other NGOs Impact on VINCI’s credibility with investors and international organisations Damage to the Group’s reputation that may affect assessments by specialised agencies	Risks inherent to the nature of construction activities: labour-intensive, cyclical character and multiplicity of participants in the value chain (subcontractors, service providers and temporary staff) Lack of staff training and/or clear guidelines, non-compliance with Group rules Expropriation of local populations by public stakeholders Possible consequences: Deterioration in relationships with stakeholders Legal proceedings and potential conflicts with employee representative bodies, human rights organisations and other NGOs Impact on VINCI’s credibility with investors and international organisations Damage to the Group’s reputation that may affect assessments by specialised agencies Risk management procedures Preparation and dissemination of VINCI’s Guide on Human Rights (https://www.vinci.com/publi/manifeste/vinci-guide_on_human_rights-en.pdf), identifying Group-level risks and the related guidelines to promote human rights Identification of potential sources of project controversy and risks incurred in regions Implementation of the appropriate legal, management and coordination tools (clauses for subcontractors and service providers, election of employee representatives, dialogue with local communities, etc.) Human rights assessments at subsidiaries Training programmes and awareness initiatives among managers and their team members Participation in sectoral and collaborative human rights initiatives Audits of subsidiaries and projects to ensure compliance with VINCI’s general guidelines and its Guide on Human Rights Support provided to subsidiaries in auditing and selecting temporary employment agencies Legal actions against unfair reputational attacks

1.4.2 Health, safety and security of employees and subcontractors

Health and safety

Employees of VINCI companies and subcontracting companies are required to work on the often complex projects and operations that the Group carries out. This can have an impact on their health, safety, hygiene and quality of life in the workplace. The health and safety coordinators of the Group’s business lines have identified several major risks.

In the event of an accident or near miss, the affected company’s business can be slowed considerably, and appropriate corrective measures must be implemented before it can be restarted.