QSE Department – 11/03/2019

Guideline for implementing a just culture policy

A just culture is one in which people feel free to report errors and unsafe conditions, even their own
errors, without fear of the bounce back upon themselves or their coworkers.

This document is intended to provide guidelines for implementing a just culture policy in Terre Armée. It is
in line with the VINCI Construction training program "Managing with Safety Focus" which is currently
deployed on a large scale.

As per CODIR decision, the just culture policy shall be implemented in every BUs. It includes two key programs
which are complementary and inseparable.

1- The incentive program.

2- The sanction program.

Safety policy performance is closely linked to the quality of feedback from the field, and consequently on the
voluntary participation of workers and staff who are in direct contact with the risks. To obtain reliable

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information, it is key to establish an organizational climate in which people are ready to report their mistakes,
near misses and unsafe situations they witness.

The collection of information from the field is more difficult when policies are based on blame and sanction.
Just culture is based on the non-punitive treatment of human errors. On the other hand, we cannot tolerate
intentional violations and serious failures. A just culture is not equivalent to a no-blame culture.

The right balance therefore consists in implementing a policy which encourages the workforce and the front-
line management to provide information from the field, and also, in which they are aware of the limits
between acceptable and unacceptable behaviors.

1- Distinguishing between different types of risk behavior

At first, it is key to distinguish between the different types of risk behavior: (1) error, (2) recklessness, and (3)
conscious infringement. The challenge is to differentiate between real “wrong behavior” and “unsafe acts”
against which sanctions might be neither appropriate nor useful.

Error

The error is always involuntary. It can result from clumsiness, inattention, lack of care, omission,
misunderstanding, miscommunication ...

Recklessness

Recklessness refers to intentional risk taking, without being fully aware of the negative consequences that
results. Without necessarily breaking a rule, a reckless person consciously disregards an obvious risk.

Conscious infringement

A conscious infringement is an intentional violation of a rule with full knowledge of the risks and the possible
negative consequences.

2- Implementing a successful incentive program

Why are incentives and rewards important?

While sanctions can be effective in the short term, they do not change the underlying motivations for
behavior in the long term. Incentives and rewards for workers are one of the ways in which you can
encourage responsible and virtuous behaviors on jobsites. They are useful to encourage people to follow
safety procedures, to reward those who achieve outstanding safety performance and those who actively
support a proactive culture, to encourage participation in safety initiatives and to more generally encourage,
reward and reinforce specific safe behaviors.

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Important points to consider

a) The reward scheme should be communicated fully to workers. Everyone should know what it takes to
achieve a reward and what observers will be looking for.

b) Making the reward scheme part of the site daily routine encourages participation.

c) Avoid rewarding the absence of unsafe behavior, focus instead on the reward of observable safe
behaviors.

d) Include agency workers and subcontractors, as well as employees.

e) Always give feedback on the outcomes. Posters, site briefings, team meetings or newsletters may be
used to recognize the winners. Communicating the number of rewards given to workers shows that they
are effective.

f) Consider the impact the rewards chosen will have on the workers. Rewards such as the safety raffle (see
below) mean that, while several people may have been seen to act safely, only one is rewarded.
g) Consider the workers’ values when choosing the type of reward. It should be noted that any scheme
should be aware of the workers’ cultural matters.
h) It is important that when individual or group targets are set all workers know how they can achieve them.
All goals must be fair and attainable.
i) Consider the use of individual and group rewards. Often group rewards work less well than individual
ones.
j) It may be useful to allow workers to give rewards to each other as a form of recognition. This means that
the reward scheme is not completely dependent on the supervisor noticing safe behaviors.

Examples of incentives

• One-off prizes, for individuals or for a group.

• Monthly gift vouchers.

• Moral incentive scheme: The BU/project gives a small amount of money to charity for each safe behavior
observed or for every person who attends a safety event.

• Safety raffle (a monthly draw for all workers who received a ticket for behaving safely).

• ‘There and then’ rewards that involve a single observed safe act resulting in a small reward. This shows
immediate recognition of a safe behavior and good practice.

• Monthly rewards that involve an accumulation of recognition by others (a ‘safe person of the month’
award).

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3- Implementing a successful sanction program

Why are sanctions important?

A permissive culture without sanction is neither realistic nor recommended. Unsafe acts are sometimes
intended and unacceptable behaviors require appropriate sanctions.

A general tolerance towards risk takers would be perceived as inconsistent with the messages we deliver and
the high ambition we have.

Important points to consider

a) The sanction policy shall comply with the local legal and regulatory requirements and with the VINCI Code
of Ethics and Conduct.

https://www.vinci.com/publi/manifeste/ETH-2017-12-EN.pdf

b) The sanction should have an educational value. The first step towards a just culture is to accept the right
to make a mistake once. The sanction scale is wide, it extends, at both ends, from an informal talk with the
supervisor to a severe disciplinary sanction as provided by the law.

• It shall be progressive: proportional to the failure and increased for repeat offenders.
• It shall be a proportionate response which shall consider possible organizational failures.

c) Only wrong behaviors and unsafe acts shall be subject to sanction, never consequences (accident severity,
damages, loses). The level of sanction to be applied shall be linked to the severity of the wrong behavior or
the unsafe act.

d) The sanction shall be applied on an objective set of facts. Beforehand, the rules shall be clear, well
understood by the workers and they shall be relevant to the given work situation. To this end, the
management shall organize proper information of employees (training, awareness, safety induction, PreStart
meeting, ToolBox talks ...) and ensure the relevance of rules and work instructions (safety plan, risk
assessment, method statement...). The boundaries between what is acceptable and what is not shall be
clearly defined and explained.

e) The sanction may apply at several hierarchical levels.

f) The sanction policy and its implementation shall be transparent. Reluctance to communicate and explain
a sanction should question on the fairness of the sanction.

g) In most cases, the sanction shall come together with reinforcement initiatives to support the sanctioned
individuals and/or their colleagues.

A typical decision tree is proposed below. It may be fully reproduced or the BU may adapt it to consider
programs already in place and local regulations.

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Example of sanctions

• Actions to promote safe work and proactive initiatives demonstrating a clear personal commitment to
safety: give testimony, lead ToolBox talks, carry out safety inspections and provide feedback…

• Verbal reprimand from the direct supervisor and/or upper management.

• Written warning.

• Disciplinary actions including suspension, transfer, demotion and dismissal.

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