2019 Annual financial report

4.4 Business ethics

Chapter 4. Corporate Social Responsibility – Non-financial performance

4.4 Business ethics

4.4 BUSINESS ETHICS

Since its creation, Publicis Groupe has focused on operating in accordance with high standards of ethics and ensures that this requirement is shared by all employees and managers.

4.4.1 Ethical principles in the conduct of business

Janus is the Group’s Code of Ethics and applies to all managers and their teams. It consists of a Code of Conduct and detailed operating rules. The Code of Conduct applies to all employees (see Section 3.1.5 of this document). 85.5% of the Group’s workforce has received training in the Janus Code and its contents. The majority of new employees, whatever their position, follow an induction program comprising a presentation of the Group and its businesses and a presentation on Janus and its key principles. This includes elements related to team and manager standards of behavior, and the operating rules to be respected in terms of fair trade. These include: the “Zero tolerance” principle in terms of discrimination, harassment, and violence at work, rules regarding conflicts of interest, fraud, anti-corruption, data protection, compliance, key points of the HR policy, and a reminder of the major principles adhered to by the Group, such as the United Nations Global Compact. 

In terms of business, one of the Group’s historical principles is its refusal to take part in partisan communications campaigns of any kind. The Group refuses to work for political parties, sects or ideological propaganda organizations. Several Janus excerpts are available on the Group’s website, in the CSR section.

4.4.2 Duty of Care Plan

In accordance with Article L.225-102-4 of the French Commercial Code, Publicis Groupe has drafted and implemented a Duty of Care plan comprising reasonable duty of care measures for the identification of risks and prevention of serious infringements in the areas of human rights and fundamental freedoms, health, personal safety and the environment, resulting from the Company’s activities and those of the companies it directly or indirectly controls, within the meaning of Article L.233-16 of the French Commercial Code, as well as the activities of sub-contractors or suppliers with which it has an established business relationship. 

Every year since 2003, the Group has recommitted to the 10 principles of the United Nations Global Compact – principles which apply to the Group’s employees and those of its subsidiaries, as well as to its suppliers. These principles are based on: 

  • the Universal Declaration of Human Rights, endorsing its article 1: all human beings are born free and equal in dignity and rights. This fundamental principle is incorporated into the Diversity, Inclusion and Anti-discrimination policy;
  • the International Labor Organization (ILO) Declaration on fundamental principles and rights at work – with scrupulous concern for freedom of expression, freedom of association, and combating child and forced labor. These principles are incorporated into Talent and Human Resources, Health and Safety at work and Data protection policies; 
  • the Rio declaration on environment and development, always aiming, since 2009, to reduce the impacts of the Group and its subsidiaries on the environment, and offsetting irreducible impacts. The Consume less & better environmental policy has the same objective and is in line with the Paris Agreement;
  • the United Nations Convention against Corruption, with the Group-wide application over the last few years of the requirements of the French “Sapin 2” Law, aimed at combating corruption as described in the Anti-corruption policy.

The principles of the United Nations Global Compact are incorporated into several sections of the Janus Code of Ethics, in particular, Talent and Human Resources, CSR – Corporate Social Responsibility and CSR Guidelines for Business (previously CSR Procurement Guidelines).

4.4.2.1 Governance and scope

A dedicated Steering Committee on Duty of Care was set up in 2017, comprising members of the Internal Audit and Risk Management Department, as well as the CSR, Procurement, Human Resources and Legal Departments. Reporting to the Group’s Secretary General, this committee is tasked with introducing, and ensuring the implementation of a Duty of Care Plan in relation to the Company’s activities and those of all its subsidiaries or companies that it controls. This plan comprises reasonable duty of care measures for the identification of risks and prevention of serious infringements in the areas of human rights, fundamental freedoms, health, personal safety and the environment, resulting from the Company’s activities and those of the companies it directly, or indirectly, controls, within the meaning of article L. 223-16 of the French Commercial Code, as well as the activities of sub-contractors or suppliers with which it has an established business relationship, where these activities relate to that relationship. 

The findings of its work are presented to the Supervisory Board’s Strategy and Risk Committee.

Internal Audit covers labor-related issues during its regular reviews (HR procedures, employee protection and information, whistleblowing system, etc.).