2025 Universal Registration Document

General and financial elements

3.3.3 Risk prevention initiatives and measures: general framework and specific initiatives(*)
3.3.3.1 Risk prevention and mitigation measures
Risk prevention, mitigation or remediation measures, according to the identified issue

Specific measures are designed to address each issue and adapted to the situation. Some examples are provided below.

Risk prevention, mitigation or remediation measures, according to the identified issue
Identified issue Risk factors Examples of prevention and/or mitigation measures (non-exhaustive list)
Labour migration and recruitment practices

Labour migration and recruitment practices

Risk factors
  • Systemic poor practices
  • Large-scale labour migration
  • Limited regulatory framework

Labour migration and recruitment practices

Examples of prevention and/or mitigation measures (non-exhaustive list)

Measures implemented by the Group:

  • Development of a set of responsible recruitment tools (Fair Recruitment Toolkit)
  • Creation of a responsible recruitment e-learning module
  • Delivery of intercompany training
  • Participation in conferences and seminars, building of partnerships
  • Adoption of the Employer Pays Principle
  • Support in drafting a standard contract with recruitment agencies
  • Participation in due diligence for recruitment agencies, including by bringing in specialised third parties
  • Training and support for teams in applying responsible recruitment tools and methodologies
  • Participation in studies of migration corridors and recruitment costs
  • Interviews conducted with migrant workers

Measures implemented by subsidiaries:

  • Creation of workers’ committees
  • Implementation of local whistleblowing procedures
  • Subcontractor audits
  • Use of the tools made available by the Group
  • Recruitment of specialists

See also paragraph 3.3.3.2, “Specific vigilance measures to fight forced labour and illegal work”, page 311.
Working conditions

Working conditions

Risk factors

Limited regulatory framework

Working conditions

Examples of prevention and/or mitigation measures (non-exhaustive list)

Measures implemented by the Group:

  • Analysis of the regulatory framework
  • Establishment of VINCI’s social protection framework
  • Study on the living wage
  • Advice on local whistleblowing procedures

Measures implemented by subsidiaries:

  • Supplemental health insurance for employees
  • Creation of workers’ representation committees in sensitive environments
  • Development of a non-discrimination policy
  • Controlled access to worksites
  • Age checks of job applicants
  • Due diligence for private security companies
  • Implementation of local whistleblowing procedures

See also section 2, “Duty of vigilance with regard to health and safety”, page 296.
Living conditions

Living conditions

Risk factors

Varying difficulties depending on the region (isolation, low hygiene standards, inadequate availability of collective accommodation centers, etc.)

Living conditions

Examples of prevention and/or mitigation measures (non-exhaustive list)

Measures implemented by the Group:

  • Spot inspections of accommodation housing direct employees or subcontractors’ employees
  • Sharing of standard tools (internal rules, checklists, etc.)

Measures implemented by subsidiaries:

  • Establishment of accommodation standards
  • Creation of equipment checklists
  • Design and implementation of assessment criteria for workers’ accommodation
  • Organisation of visits by managers
  • Preselection of decent accommodation for each operating site
  • Advance technical inspections to ensure that all equipment meets standards (for hygiene, electricity, gas, etc.)
Value chain

Value chain

Risk factors
  • Limited regulatory framework
  • Poor practices by players in the value chain
  • Limited or inadequate application of regulations

Value chain

Examples of prevention and/or mitigation measures (non-exhaustive list)
  • Measures similar to those described above can be taken, since the same issues are relevant to subcontractors, on-site service providers and suppliers.
  • See paragraph 3.2, “Human rights and health and safety in the value chain (ESRS S2)”, of the sustainability report, page 269.
  • The Group also provides methodologies for a critical review of subsidiaries’ existing measures to assess their effectiveness and the need to modify practices. A responsible subcontracting toolkit, presented as a microsite, will be published in early 2026.
Local communities

Local communities

Risk factors
  • Inadequate regulatory framework with regard to impact assessment as well as consultations with affected communities
  • High-impact project
  • Role as the concession holder or the prime contractor

Local communities

Examples of prevention and/or mitigation measures (non-exhaustive list)

See paragraph 3.3.2.2, “Preventing negative impacts on local communities”, of the sustainability report, page 279.

Measures to reduce or mitigate risks relating to players in the value chain vary depending on the situation, the service being provided and the risks identified. They can be taken at different levels of the organisation: Group, business line, division or subsidiary.

For example, in respect of temporary employment agencies (TEAs), the Group’s Purchasing Coordination unit has set up a framework agreement to select approved agencies, which must be used by VINCI’s companies in France. Temporary employment is a major purchasing category in France to which the Group associates a high degree of social risks to temporary workers, such as risks surrounding recruitment, working conditions and living conditions. During the latest renewal process in 2023, all of the assessed TEAs answered a mandatory sustainability questionnaire with six separate sections: recruitment and employment conditions, occupational health and safety, non-discrimination, training and skills development, prevention of illegal or undeclared work, and the availability of a whistleblowing system. Audits of 14 of the agencies were carried out, either because their questionnaire results were unsatisfactory or because alerts were received by the Purchasing Coordination unit. In all, 43 of the 144 assessed TEAs were excluded on the basis of ESG criteria or audits. A new contract for 2023 to 2025 was signed with 89 TEAs, and an ESG improvement action plan was established for 24 of them.

(*) The following information corresponds to required disclosures in the sustainability report (S2-2 and S2-4).