The Declaration on Essential and Fundamental Actions Concerning Occupational Health and Safety, issued jointly by VINCI and its European Works Council, provides a reference framework in the areas of health protection and the prevention of occupational risks. It is available in 24 languages and covers more than 98% of the Group’s employees.
VINCI’s Environmental Guidelines, also issued as a joint declaration, provide a framework for reducing environmental impacts and risks associated with the Group’s activities. They apply to all Group companies to improve and adapt their environmental actions to needs on the ground. All subsidiaries are responsible for ensuring that actions are also taken accordingly by subcontractors and joint contractors throughout projects. These guidelines are available in 14 languages.
The All-round Performance Charter for Purchasing Partners sets out the Group’s commitment to encouraging its purchasing partners to adhere to its all-round performance policy. This document is available in five languages.
In addition to these reference documents, the Group’s Anti-corruption Code of Conduct details the rules set out in the Code of Ethics and Conduct concerning the prevention of all acts of corruption, notably by identifying risks and defining the behaviours and practices to be avoided. These two documents apply to all Group employees and are available on the Group’s website and its intranet. They are frequently used as references at seminars and in company agreements.
The Group has also issued recommendations on the conditions for introducing and rolling out measures to prevent and detect risks of non-compliance with Group policies.
Dedicated governance informs and promotes the Group’s corporate culture around business conduct.
In particular, the professional ethics policy is an overarching commitment implemented under the initiative of the Chief Executive Officer, who has added a foreword to the VINCI Manifesto, the Code of Ethics and Conduct and the Anti-corruption Code of Conduct.
The Group’s Executive Committee plays a key role in defining, disseminating and promoting business conduct policies. The general guidelines sent by VINCI’s Executive Management to each operational member of the Executive Committee contain a special section on their obligation to implement compliance programmes within their scope of responsibility.
The Ethics and Vigilance Committee – made up of seven members, five of whom are from the Executive Committee – is responsible for implementing compliance systems, notably those concerning anti-corruption covered by the Code of Ethics and Conduct, resulting from the Group’s business activities. It issues recommendations, assesses the Group’s anti-corruption system and suggests any necessary changes. It met four times in 2025 and reports annually on its activity to the Strategy and CSR Committee of the Board of Directors.
Members of the Executive Committee and the Ethics and Vigilance Committee receive training on business conduct. Their knowledge of the subject is updated regularly at a dedicated Executive Committee meeting that takes place at least once a year. These members have a good, collective understanding of all topics relating to business conduct and are in a position to promote it within the Group’s culture.
The Strategy and CSR Committee of the Board of Directors regularly monitors the progress of initiatives taken by the Group relating to business ethics. Its members have expertise in business conduct, as detailed in paragraph 3.1.2, “Areas of expertise of Board members”, of chapter C, “Report on corporate governance”, page 132.
The Responsible Procurement Committee defines and coordinates the approach to promoting responsible procurement within the Group.
VINCI SA’s Ethics and Vigilance Department monitors and coordinates ethics activities through a network of ethics officers. It promotes a compliance culture and Group values to facilitate the communication and implementation of compliance goals by the business lines. The department also oversees the Ethics and Vigilance Committee and the Ethics and Compliance Club.
The Ethics and Compliance Club is made up of the Chief Ethics and Vigilance Officer, the General Counsel, the Chief Audit Officer, ethics and vigilance managers at Group level, and compliance officers and managers from each business line. It keeps close tabs on related legislation and promotes best practices. Certain members participate in collaboratively developing Group risk management measures. For example, in 2025, some of them worked on creating a new anti-corruption e-learning module.
All Group employees have access to several reporting channels. They can refer matters to their managers, use their business unit’s local whistleblowing system or directly contact the Ethics and Vigilance Department at Group level.
Employees can also decide to go through the human resources departments, health and safety representatives or employee representative bodies. They are informed of the reporting channels available to them via internal communication on the Group’s intranet, internal memos and postings, or at orientation days for new hires, company seminars and in training sessions.
VINCI has implemented an internal reporting system that allows all Group employees, but also other stakeholders, to report any behaviour or situation that infringes its Code of Ethics and Conduct, Anti-corruption Code of Conduct or rules applicable to human rights and fundamental freedoms, human health and safety, or environmental concerns, and more broadly any crime or infringement of national or international law, as well as any threat or harm to the public interest.
Employees are informed about this system through the internal communication channels mentioned above. Stakeholders are also informed about the existence of this system through framework agreements, which include a specific clause pertaining to the subject, and in the All-round Performance Charter for Purchasing Partners (subcontractors, suppliers and service providers).
