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2013-vinci-annual-report

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COMPLY WITH ETHICAL<br />

PRINCIPLES TOGETHER<br />

We commit to ensuring total transparency in our<br />

own practices and in those of our subcontractors.<br />

26 GROUP / SUSTAINABLE DEVELOPMENT<br />

Ethical standards form the<br />

bedrock of mutual trust<br />

between our customers and us.<br />

It is therefore essential that our<br />

employees everywhere share<br />

and apply rules that ensure<br />

compliance with these<br />

standards. Moreover, as a<br />

major player in the sector,<br />

we have a duty to constantly<br />

raise the level of ethical<br />

standards and transparency<br />

beyond the requirements set<br />

out in legislation.<br />

Main actions<br />

•<br />

In 2010, VINCI published its<br />

Code of Ethics and Conduct,<br />

which forms the basis for its<br />

view of this subject. Additional<br />

to the general directives issued<br />

to the heads of VINCI business<br />

lines, this document sets out<br />

all the rules of conduct<br />

applicable to all companies<br />

and employees. These rules<br />

are circulated to all levels of<br />

management in the business<br />

units, and in particular to each<br />

new manager taking up his or<br />

her duties. The code also spells<br />

out the rules for external<br />

partners. It has so far been<br />

circulated to 6,909 managers;<br />

6,589 acknowledged receipt,<br />

giving a response rate of 95.4%.<br />

Each division has introduced<br />

appropriate training and<br />

follow-up procedures. For<br />

example, Eurovia introduced<br />

quarterly checks on compliance<br />

with the code; at the end<br />

of <strong>2013</strong>, 100% of employees<br />

involved – head office employees<br />

and agency managers –<br />

applied the rules of the code,<br />

which is available on the<br />

Group website (*) .<br />

• VINCI has also appointed an<br />

Ethics Officer, who operates<br />

under considerable autonomy.<br />

The Ethics Officer’s task is<br />

to work with the operational<br />

and functional departments to<br />

ensure that the code is<br />

understood and applied.<br />

Any employee who encounters<br />

difficulties or has questions<br />

about the scope and implementation<br />

of these rules may consult<br />

the Ethics Officer, especially<br />

with regard to operations in<br />

countries considered as<br />

potentially at risk. In <strong>2013</strong>, the<br />

Ethics Officer directly handled<br />

all cases submitted, in<br />

accordance with clear and<br />

explicit guidelines: confidentiality,<br />

inquiry, and internal and<br />

external investigation, if<br />

required. Additionally, internal<br />

audit resources and comprehensive<br />

audit plans govern the<br />

overall system.<br />

• The Ethics and Compliance<br />

Club, which brings together<br />

the Group’s legal affairs<br />

directors and the Ethics<br />

Officer, continued its work.<br />

Its remit is to foster exchanges<br />

of best practices in the field of<br />

ethics, to perform a legislative<br />

and regulatory watch, and to<br />

review cases.<br />

• VINCI companies operating<br />

in sectors in which specific<br />

ethics procedures apply have<br />

appointed their own specialised<br />

compliance officers.<br />

The resultant ethics arrangements<br />

therefore comply with<br />

the standards applied by the<br />

most stringent clients and<br />

countries.<br />

• VINCI established a Human<br />

Rights Committee in <strong>2013</strong>.<br />

Its members are in particular<br />

the human resources managers<br />

of companies located in<br />

potentially sensitive regions.<br />

It produced a review document<br />

that identifies the risks<br />

and conduct to adopt for each<br />

of the various human rights<br />

(see p. 182).<br />

(*) www.<strong>vinci</strong>.com/<strong>vinci</strong>.nsf/en/page/<br />

code-of-ethics.htm<br />

95.4%<br />

of employees concerned<br />

by the Code of Ethics<br />

and Conduct have signed<br />

up to it.<br />

PROGRESS<br />

TARGETS<br />

VINCI aims to have 100% of<br />

the employees concerned by the<br />

Code of Ethics and Conduct<br />

signed up, especially newly hired<br />

managers and managers from<br />

companies acquired by the<br />

Group. In addition to this target,<br />

the other areas of progress<br />

concern mapping the signatories<br />

to the code and management<br />

training in this area.

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