2025 Universal Registration Document

VINCI’s approach to human rights risk management involves the following steps and actions:

3.1 Governance of the human rights component of the duty of vigilance plan

A dedicated governance structure

A dedicated governance structure The Group’s approach to human rights is supported at the executive level and coordinated by VINCI’s Vice-President for Human Resources, who sits on the VINCI Executive Committee. The Human Rights Steering Committee, made up of the human resources directors of the Group’s business lines and divisions, provides additional support, facilitating decision-making, discussion and collaboration among these entities. Members are responsible for communicating the approach to their respective management committees and rolling it out in their respective business lines and divisions. At every meeting, the committee assesses the progress made. At the operational level, the Group’s human resources professionals are on the front line ensuring the implementation of the human rights approach, as are its operational managers, who occupy key roles in the organisation and uphold the Group’s commitments across its companies and through all their projects.

Each year, the implementation of the human rights approach is presented to the Strategy and CSR Committee of the Board of Directors and discussed with the European Works Council.

The Social Responsibility Department, reporting to the Human Resources Department, coordinates the human rights approach on a continuous basis, sharing its expertise with business lines and divisions to help them incorporate and implement Group measures, develop risk mapping and assessment tools, evaluate subsidiaries, keep track of regulatory changes in due diligence and human rights matters, train and build awareness among employees and management committee members and communicate with Procurement, Internal Control, Ethics, Environment, Security, Social Affairs and other departments as well as the Health and Safety Task Force. The team is in frequent contact with civil society organisations, investors, institutions, and other external parties to address identified issues, answer questions and provide further information about the measures taken in the Group. In some sensitive areas, the divisions have hired social responsibility coordinators to directly assist operational teams with implementing and monitoring initiatives.

Active dialogue with stakeholders

Due to its wide range of business activities and countries of operation, the Group’s entities interact with many stakeholders of diverse natures. One level of dialogue takes place at the entity level, in an operating context, but the Group also regularly communicates with stakeholders at a higher level to refine and improve its policies in general and assist entities as needed. The following table summarises the main categories of stakeholders with whom the Group dialogues.