The Group’s Purchasing Coordination unit monitors these action plans (see section 2, “Duty of vigilance with regard to health and safety”, page 296). In addition to implementing its action plan, each TEA working with a Group entity must meet VINCI’s requirements for all suppliers in the purchasing category, which cover safety reporting, PPE quality, mandatory training, declaration of temporary workers and minimum pay, among other specifications.
Group companies also implement controls during the performance of contracts with agencies, to prevent risks of infringing workers’ rights. For example, payroll systems are checked to ensure that all hours worked are being paid and that the required social contributions and declarations are being made to the relevant organisations, ensuring that workers access the social benefits to which they are entitled.
Regarding other suppliers, see paragraph 3.2, “Human rights and health and safety within the value chain (ESRS S2)”, of the sustainability report, page 269.
Lastly, Group entities take remedial action based on their situation, most often in response to concerns reported through whistleblowing procedures. Remedial measures generally focus on suppliers and consist, for example, in establishing formal employment contracts as well as settling overdue wage payments and unpaid overtime.
VINCI schedules follow-up assessments for some of the action plans implemented following a human rights audit conducted by assessors in the Group, its business lines and its divisions. The establishment of formal practices, such as for managing relations with local communities, managing social risks in subcontracting, and implementing whistleblowing procedures are among the main areas frequently identified as needing improvement.
One way subsidiaries can help ensure social compliance from subcontractors is by updating their contract templates to include detailed clauses on managing social risks, holding subcontractors to a higher standard than local labour law, and/or applying such clauses to a wider range of partners. Improvement action plans also generally seek to develop and implement measures to verify compliance with employment-related criteria, in particular for the categories of subcontractors or service providers that present the highest risk. Examples of measures include social audits at subcontractors and service providers and better integration of human rights considerations into the various stages of contract management. Subsidiaries engaged more deeply with subcontractors on working conditions, which led to improvements such as whistleblowing procedures, workers’ committees and supplemental health insurance to offer workers better coverage, especially where public healthcare systems are weak. In addition to bringing remedial action, stronger engagement can lead to improved practices.
Assessed subsidiaries were also encouraged to improve their whistleblowing procedures in various ways, such as by raising worker awareness of the whistleblowing system, applying it more explicitly to human rights concerns, opening it up to subcontractors and service providers working on a site, and making its rules of use more transparent. Assessments sometimes led subsidiaries to enrich their employee surveys with questions about working conditions. According to the interviews conducted during audits, worksite employees tend to first turn to their immediate supervisor if they experience any problems or difficulties. Often, significant work is required to develop and disseminate a second-level grievance procedure as an alternate channel, if needed.
In subsidiaries where employers are responsible for workers’ accommodation, checklists were rolled out to ensure regular and consistent verifications of the living conditions of workers, including those of subcontractors. Company managers also conduct on-site inspections of workers’ accommodation.
The increased number of assessments has encouraged subsidiaries to share practices and experience among themselves. Audit recommendations are tailored to subsidiaries’ practices and situations so they can be effectively applied in the relevant operational environments. For example, a subsidiary may be advised to incorporate social risk prevention into the checklists used by their managers for site inspections or into the mobile applications that have already been developed for health and safety visits, rather than create new tools.
Alongside its general approach to managing identified human rights risks, VINCI has also developed ad hoc programs and initiatives to address risks considered to be major either due to their severity for affected third parties or due to their likelihood of occurrence in some parts of the world. This part of the duty of vigilance plan describes two of these programmes.
The Group has long been committed to the fight against forced labour and has adopted the Employer Pays Principle supported by the Institute for Human Rights and Business (IHRB).(**) Because forced labour is such a serious risk for people, VINCI is particularly aware that special scrutiny must be paid to the conditions in which migrant workers are recruited and employed, whether directly or indirectly, via temporary employment agencies or subcontractor companies.
The underlying factors driving forced labour can vary from region to region. VINCI considers that this issue must be handled close to where the problem occurs in order to take effective actions that suit the on-the-ground realities. The risk of forced labour can come from certain legislative frameworks that do not align with international conventions or arise from unfair local practices, which are sometimes deeply embedded. Many problems arise early in the recruitment phase, even before workers arrive at the project site or are hired by the Group.
