2025 Universal Registration Document

General and financial elements

On 6 November 2020, Xavier Huillard, Chairman and Chief Executive Officer of VINCI, and Roberto Migliardi, Secretary of VINCI’s European Works Council, signed VINCI’s Environmental Guidelines (www.vinci.com/publi/manifeste/dir-env-2020-11-en.pdf). This document provides a framework for reducing environmental impacts and risks associated with the Group’s activities. It applies to all Group companies and each subsidiary is responsible for ensuring that appropriate actions are also taken by subcontractors and joint contractors throughout projects.

The Group’s Environment Department shapes the environmental component of the duty of vigilance plan, based on the environmental goals shared by VINCI’s business lines and entities for the three targeted areas. VINCI’s environmental ambition extends the environmental actions of VINCI companies beyond compliance with the regulatory requirements of the countries in which they operate.

Measures to identify and prevent environmental risks are largely influenced by the geographical locations of companies and their activities as well as the vulnerability of the surrounding areas. The Group’s environmental policy is translated into operational guidelines in each of its business lines. Each business line establishes a road map taking into account the specific nature of its activities and regions, with the aim to drive continuous improvement. In subsidiaries, chief executives and senior management are in charge of ensuring regulatory compliance and the implementation of risk prevention procedures in their operational scope, taking into account their specific activities and challenges. They are assisted by the network of environment officers who provide environmental expertise (see paragraph 1.3, “ESG risk management and internal control”, of the sustainability report, page 196).

4.1 Mapping of the Group’s major environmental risks

In 2025, in accordance with the EU’s Corporate Sustainability Reporting Directive (CSRD), VINCI updated its environmental risk map to reflect the material negative impacts identified in the double materiality assessment that was conducted in 2024. The potential severity of these impacts was assessed based on the scale, scope and irremediable character of the impact. The assessment process is described in detail in paragraph 1.1.2, “Double materiality assessment”, of the sustainability report, page 187.

The Group’s gross environmental risks identified as priorities within the scope of its duty of vigilance are presented below:

  • risk of negative impact related to the Group’s contribution to climate change;
  • risk of negative impact related to waste produced by the Group’s activities (degradation of natural spaces and habitats and pollution of soil, water, and air);
  • risk of negative impact related to a depletion of natural resources (due to the use of construction materials of mineral or forest origin,etc.);
  • risk of negative impact related to the degradation of natural environments due to water withdrawals and consumption for operations at the Group’s fixed sites and in its upstream value chain;
  • risk of negative impact on ecosystems, flora and fauna related to the Group’s operations located close to or inside protected areas, UNESCO sites, key biodiversity areas or sensitive areas;
  • risk of negative impact related to soil sealing resulting from the Group’s new construction and earthworks activities and its extraction of raw materials.
4.2 Assessing the situation of subsidiaries, subcontractors and suppliers
4.2.1 Assessing the situation of subsidiaries and subcontractors

Multiple environmental assessment processes are in place across the Group to fulfil regulatory requirements, meet stakeholder expectations and comply with internal company policies. The very first principle laid out in the aforementioned Environmental Guidelines refers to identifying and assessing risk.

Environmental certification

Most Group entities assess their performance by implementing an effective environmental management system and obtaining ISO 14001 certification. Environmental management systems guarantee a robust level of risk prevention and management through annual external audits. VINCI encourages its subsidiaries to obtain environmental certification such as ISO 14001 to improve the effectiveness of their environmental management systems. The percentage of the Group’s activity covered by ISO 14001 certification is calculated in relation to revenue or another relevant indicator, depending on the business line. ISO 14001 certification covered 69% of VINCI’s revenue in 2025 (see paragraph 1.3.2, “ESG risk management and internal control, of the sustainability report, page 196).

Third-party controls

The activity of the Group and its subcontractors is also regularly reviewed by other external bodies:

    • Government agencies carry out inspections to ensure compliance with regulations on worksites.
    • Customers and program managers mandate design offices to conduct environmental audits of worksites on a regular basis, to monitor compliance with the Group’s regulatory and contractual obligations.
    • Nearby residents and local civil society organisations increasingly scrutinise construction and quarry sites, especially when a consultation process has been established that enables partner organisations to visit the site and verify that the commitments made are being fulfilled.
    • Financial institutions and international financing providers sometimes take special measures to monitor projects with a high risk of environmental impact.
    • More specifically, independent design offices perform audits on worksites to check compliance of waste storage, processing and disposal procedures.

When any non-compliance is identified through these audits or monitoring processes, the onus is on the companies responsible to explain the shortcomings and promptly correct them.

Internal control

The Group’s Executive Committee and Board of Directors examine and approve material ESG impacts, risks and opportunities each year, relying in particular on the work of the Audit Committee (see paragraph 1.3.2, “ESG risk management and internal control”, of the sustainability report, page 196). Given VINCI’s decentralised organisation, the Environment Department ensures that the Group’s environmental rules and procedures are applied by business lines and provides them with technical assistance while respecting their freedom over operational decisions. In business lines and divisions, environmental correspondents regularly carry out inspections and audits of internal as well as subcontractors’ operations. Group companies measure the environmental footprint of their projects and activities and report on the internal and external resources implemented to protect the environment.