2025 Universal Registration Document

General and financial elements

3.3.2 Assessing human rights risk management performance at subsidiaries

To guide Group subsidiaries in developing appropriate risk prevention and mitigation measures with regard to their activities, operations and management systems (policy, procedures, tools, etc.), the Group has designed frameworks for assessing the major identified risks.

Managing Human Rights, a tool to assess subsidiary practices

The Managing Human Rights platform developed by VINCI is used to evaluate whether the management systems implemented by subsidiaries conform to the Group’s guidelines and whether they specifically address and prevent the identified risks in the subsidiary’s own operations and in its relations with subcontractors and temporary employment agencies. Once it has been assessed, the entity or project then reports on the results and improvement plan to its division’s Human Resources Department, which in turn informs the Group through its representative on the Human Resources Steering Committee. As necessary, major risks are monitored at Group level.

For example: Has the company checked that the workers did not have to pay a recruitment fee? Has it checked that the hours worked by temporary workers and subcontractors’ employees on its sites are accurately recorded and that social contributions are fully paid? Has it ensured that there are systems in place to inform and consult local residents and communities that could be impacted by projects? The 200 questions are precise, concrete, and relate to the five salient human rights issues and 17 themes (see “Identification of material issues” in paragraph 3.2, “Mapping of the Group’s major human rights risks”, page 305). The four response options range from “no practices” (Level 1) to “best practices” (Level 4). Each response option is tailored to the question to help operational teams recognise and understand the practices that should be implemented.

An assessment performed by the Group is carried out over several days and involves collaborative group sessions bringing together operational managers and members of the management committee of the entity or project. The assessment therefore involves all the management teams of an entity or a project, together with its human resources, health and safety, finance, legal, procurement and other support functions, for several days. Visits are also made to examine sites and worker accommodation. Interviews may be conducted with employees, temporary workers and/or employees of subcontractors, as well as representatives of subcontractors or temporary employment agencies.

After completing the assessment, the entity or project receives an evaluation of its practices and recommendations for building an action plan. Not only do these assessments deliver a very operational view of the Group’s human rights principles, they also promote the spread of best practices. Additionally, they provide opportunities to share the many tools that already exist – for recruiting ethically, eliminating discrimination, implementing a whistleblowing procedure, managing social risks in subcontracting, and so on – to enhance human rights risk prevention and mitigation. A monitoring procedure is then set up to track the subsidiary’s progress in implementing its action plan.

The Managing Human Rights platform has been made available in English, French and Spanish on the Group’s intranet, vinci.net, so that VINCI’s more than 293,000 employees can become aware of and engage with human rights issues. In addition to an assessment by the Group’s human rights coordinators, subsidiaries can choose to self-assess their performance with regard to all or some human rights issues. The Managing Human Rights platform is therefore an essential component of VINCI’s efforts to promote human rights. At end-2025, 146 subsidiaries and active projects in 50 countries had been assessed by the Group’s human rights coordinators using the platform (see paragraph 3.4, “Monitoring implementation and effectiveness”, page 314).

Assessing the situation of subcontractors and on-site service providers

In VINCI’s business sectors, whether involving concessions, energy or construction activities, the major challenges arise at operational level. Accordingly, when it comes to vigilance with regard to human rights risks in the value chain, priority is given to subcontractors, service providers and temporary workers employed at worksites and operating sites.

The Group has provided all entities with a due diligence methodology that includes the following steps: mapping human rights risks for subcontractors and service providers, applying specific criteria during the selection phase, including specific clauses in contracts and monitoring compliance with contractual obligations. Likewise, subsidiaries can use the Managing Human Rights platform to assess their knowledge of the working and employment conditions applied by the subcontractors and temporary employment agencies with which they collaborate. The tool also enables them to evaluate how they manage social risks in subcontracting and temporary employment. Verifications and audits are carried out on a case-by-case basis. To help business lines and divisions implement the methodology, the Group has launched various initiatives.

In addition, since 2023, a multidisciplinary task force – bringing together operational team members and representatives from the procurement, human resources, finance, social affairs and risk prevention departments of business lines and divisions – has been developing a toolkit and user’s guide to strengthen the prevention of social risks in subcontracting. The guide explains the measures that are recommended to prevent and manage social risks for people working at sites controlled or operated by Group companies, at every phase of a contractual relationship (see also paragraph 3.3.3.2, “Specific vigilance measures to fight forced labour and illegal work”, page 311).