2025 Universal Registration Document

General and financial elements

Every organisational level is free to broaden the definition of positions at risk and decide which employees within its business scope will also take the anti-corruption training available within the business lines.

Information to be reported

(Active employees = employees currently working within the Group)

Group “Anti-corruption” e-learning module (A)(*) Group “Conflicts of Interest” e-learning module (B)(*)
Number of active employees trained (at 31 December 2025, regardless of year training took place, including 2025)

Number of active employees trained (at

31 December

2025, regardless of year training took place, including 2025)

Group “Anti-corruption”

e-learnin

g module (A)

(*)

112,000

Number of active employees trained (at

31 December

2025, regardless of year training took place, including 2025)

Group “Conflicts of Interest”

e-learning

module (B)

(*)

100,000

Total hours of training delivered at 31 December 2025 (only active employees at 31 December 2025)

Total hours of training delivered at

31 December

2025 (only active employees at 31 December 2025)

Group “Anti-corruption”

e-learnin

g module (A)

(*)

37,333

Total hours of training delivered at

31 December

2025 (only active employees at 31 December 2025)

Group “Conflicts of Interest”

e-learning

module (B)

(*)

20,000

Number of active employees trained between 1 January and 31 December 2025

Number of active employees trained between 1 January and

31 December

2025

Group “Anti-corruption”

e-learnin

g module (A)

(*)

28,000

Number of active employees trained between 1 January and

31 December

2025

Group “Conflicts of Interest”

e-learning

module (B)

(*)

29,000

Total hours of training delivered between 1 January and 31 December 2025 (only active employees at 31 December 2025)

Total hours of training delivered between 1 January and

31 December

2025 (only active employees at

31 December 2025

)

Group “Anti-corruption”

e-learnin

g module (A)

(*)

9,333

Total hours of training delivered between 1 January and

31 December

2025 (only active employees at

31 December 2025

)

Group “Conflicts of Interest”

e-learning

module (B)

(*)

5,800

Length of training

Length of training

Group “Anti-corruption”

e-learnin

g module (A)

(*)

20 minutes

Length of training

Group “Conflicts of Interest”

e-learning

module (B)

(*)

12 minutes

Frequency

Frequency

Group “Anti-corruption”

e-learnin

g module (A)

(*)

At least once since hire Unlimited availability

Frequency

Group “Conflicts of Interest”

e-learning

module (B)

(*)

At least once since hire Unlimited availability

Information to be reported Anti-corruption training delivered at business lines excluding Group e-learning modules (A) and (B)
Number of active employees trained on anti-corruption at 30 November 2025

Number of active employees trained on anti-corruption at

30 November

2025

Anti-corruption training delivered at business lines excluding Group e-learning modules (A) and (B)

34,000

Number of targeted active employees to be trained in 2025

Number of targeted active employees to be trained in 2025

Anti-corruption training delivered at business lines excluding Group e-learning modules (A) and (B)

14,800

Number of targeted active employees trained on anti-corruption between 1 January and 30 November 2025

Number of targeted active employees trained on anti-corruption between 1 January and 30 November 2025

Anti-corruption training delivered at business lines excluding Group e-learning modules (A) and (B)

11,500

Percentage of targeted active employees trained between 1 January and 30 November 2025

Percentage of targeted active employees trained between 1 January and 30 November 2025

Anti-corruption training delivered at business lines excluding Group e-learning modules (A) and (B)

77%

Number of active employees who voluntarily took anti-corruption training between 1 January and 30 November 2025

Number of active employees who voluntarily took anti-corruption training between 1 January and 30 November 2025

Anti-corruption training delivered at business lines excluding Group e-learning modules (A) and (B)

2,800

Total hours of anti-corruption training delivered between 1 January and 30 November 2025

Total hours of anti-corruption training delivered between 1 January and 30 November 2025

Anti-corruption training delivered at business lines excluding Group e-learning modules (A) and (B)

41,328

NB: To enhance readability, the numbers reported were rounded down to the nearest hundred or thousand.

(b) Detection measures

Whistleblowing reporting and processing procedures. One of the key measures for detecting potential corruption is to implement whistleblowing reporting and processing procedures, as described in paragraph 4.2.3, ”Identification and detection of risks”, page 284.

In 2025, the Group received a total of 1,016 internal reports processed via local procedures for raising concerns and VINCI Integrity. Around 33% of these reports related to business conduct, 50% to discrimination and harassment, 8% to other human rights issues, and 2% to the environment.

Anti-corruption controls. The Group’s accounting processes, which include anti-corruption accounting controls, contribute to detecting cases of corruption. Second-level controls are implemented to check the application and effectiveness of anti-corruption measures. In addition, the internal audit plans and self-assessment processes, overseen by the finance teams, include a series of questions aimed specifically at ensuring that anti-corruption systems do exist and are efficient.

At one of its meetings in 2025, the Ethics and Vigilance Committee focused on the presentation of each business line’s anti-corruption control plan.

(c) Remediation measures

The Anti-corruption Code of Conduct stipulates that any violation of applicable anti-corruption laws and regulations and any violation of the code can lead to disciplinary action. The law stipulates appropriate sanctions and proceedings that apply to the employee concerned.

4.3.3 Incidents of corruption or bribery

During the reference period, the Group was not convicted of any corruption or bribery charges.

4.4 Supplier relations
4.4.1 Risk management

In line with the Group’s decentralised structure, each subsidiary carries out a proportionate review (type of purchases planned, identified risks, company size) and selects its purchasing partners based on their ability to honour the commitments expected by the Group, as stipulated in the All-round Performance Charter for Purchasing Partners. The Group’s policy in this area is described in paragraph 3.2.2.1, “Human rights and health and safety issues for procurement and subcontracting”, page 269.

4.4.2 Payment practices

Each subsidiary is responsible for ensuring its compliance with the statutory or contractual payment terms that apply to it. Depending on specific local regulations and practices, subsidiaries implement tools to monitor this compliance. The Group has no management indicator to monitor this point at the consolidated level.