2025 Universal Registration Document

General and financial elements

Human rights assessments carried out across the Group since 2018 (*)
  • Evaluators from the Group’s head offices, business lines and divisions have conducted assessments in 50 countries (44 at end-2024).
  • A total of 146 Group subsidiaries and active projects have been assessed, accounting for 14% of the Group’s international subsidiaries (138 at end-2024, accounting for 15% of the Group’s international subsidiaries).
  • In 2025, 28 subsidiaries and projects underwent assessments, including 14 follow-up audits (60 subsidiaries in 2024 and 17 follow-up audits).
  • In all, these human rights assessments covered more than 45,000 VINCI employees in 2025, close to 24% of the Group’s workforce outside of France (38,000 employees and 22% of its workforce outside of France in 2024).
  • Assessments are carried out in all regions of the world, including Europe, and cover, to date, 67% of the workforce in non-OECD countries, 73% of the workforce in Africa, 59% in Latin America and the Caribbean and 64% in Asia and the Middle East.

(*) This count includes only subsidiaries and projects that are still active and in the Group. Any completed projects or sold subsidiaries that may have been assessed are therefore excluded. The assessments are only those carried out by the Social Responsibility Department or by specially trained evaluators in business lines and divisions.

In some cases, the Group may arrange for independent audits or other external controls to manage major risks, as it did in Qatar(*) and Cambodia, for example.

Especially in the context of a major project, the Group sometimes employs independent service providers to assist teams in assessing human rights risks and designing impact mitigation early on, for example, during bidding or the preparation phase once a contract has been awarded.

Reporting progress to executive bodies

The Human Rights Steering Committee monitors implementation of the road map and discusses it with the Strategy and CSR Committee of the Board of Directors.

The Group’s business lines and divisions continue to use indicators to track the advancement of human rights assessments and report on progress to their management. For example, VINCI Construction Grands Projets has developed a set of indicators that it monitors and presents monthly to the management committee. The indicators provide information on assessments performed, follow-up, progress, and the resolution of non-compliance. At VINCI Construction, two presentations of its human rights performance were also made to the management committee of Freyssinet in 2025.

Increasing integration of human rights into the Group’s internal controls

VINCI’s internal control system has been expanding its focus to increasingly include human rights. In addition to reinforcing risk committee reviews of environmental and social risks, and as a complement to the controls performed by business lines and divisions, the Group may initiate unannounced verifications of compliance with the rules set out in its reference documents.

The audits led by VINCI’s internal control team may include questions on human rights issues, developed on a case-by-case basis in collaboration with the Social Responsibility Department and tailored to a subsidiary’s business activities or country of operation. In 2025, four of the audits performed by the Internal Audit Department included an assessment of human rights risk prevention and involved the Social Responsibility Department. Similarly, a representative of the Internal Audit Department takes part in some of the assessments led by the Social Responsibility Department, which also stepped up its joint initiatives with internal control teams within the Group’s business lines and divisions in 2025. It gave a presentation on human rights assessments on Internal Control Day and later delivered a training course for internal auditors (see “Fostering a culture of human rights risk prevention through training and awareness-raising” in paragraph 3.3.1, “Cross-business initiatives and measures”, page 307).

VINCI’s annual internal control survey has included a section on preventing human rights risks for the past eight years. The survey aligns with the requirements of the reference framework published by the Autorité des Marchés Financiers (AMF, the French securities regulator), which states that parent companies must ensure that subsidiaries have risk management and internal control systems. In 2025, the questions covered topics such as the dissemination of VINCI’s Guide on Human Rights and participation in the human rights risk awareness e-learning course across the Group, but also collected data on employees’ working hours, subsidiaries’ verification of the working conditions of temporary workers and subcontractors’ employees, and the availability of a whistleblowing system. Survey findings are presented to the heads of internal control, the members of the Human Rights Steering Committee and the members of the Board of Directors and shared with the business lines and divisions. The Group also uses the survey results to adapt or reinforce certain initiatives.

4. Duty of vigilance with regard to the environment

VINCI’s environmental issues are managed at the highest level of responsibility by the Strategy and CSR Committee of VINCI’s Board of Directors, which ensures that they are integrated into the Group’s strategy (see paragraph 1.2.1, “ESG governance”, of the sustainability report, page 194). In 2019, awareness of the climate emergency and the environment became more acute, leading to the definition of a new environmental ambition involving all VINCI entities for the 2020-2030 period. It targets three areas, aligning with the key challenges faced by the Group’s businesses: climate change, the circular economy and the preservation of natural environments. The Environment Department coordinates the ambition across the Group’s entities and each year it reports twice to the Executive Committee and three times to the European Works Council. It chairs monthly meetings of the Environmental Committee, whose members are the environmental managers and directors of the Group’s business lines, and coordinates the network of more than 800 environment officers.