The ViewModel is there to decouple the UI Code from the UI Design (E.g. XAML). [Separation of Concerns of Designer and Developer, Automated testing of UI Code, etc]
Ideally the code-behind file of the View will be empty (except the call to InitializeComponent) and all UI logic and state will be handled by the ViewModel. However, in practice there might be some specific UI manipulation that cannot be handled by data-binding alone and you will need to resort to code. Such code should be placed in the code-behind.
In your case, the logic for (a) when and (b) which item to scroll to must be in the ViewModel (not in the View). Only any additional logic required to perform the actual scrolling in the ListView will be in the View code-behind.
Yes, an event would be the ideal way to do this, to avoid having any references to the View inside the ViewModel. I would recommend however to create a custom event in the ViewModel (e.g. OnFirstItemInViewChanged with arguments the item to scroll to) and in the View code-behind register to this event and just call ListView.ScrollIntoView(item).
Note:
WinForms DataGridView had a property FirstDisplayedScrollingRowIndex. If there was something similar in WPF ListView, you could solve this by binding this property to a ViewModel property, therefore leaving the code-behind completely clean.