As part of their regular tasks in the agencies, the internal audit teams spend time reminding everybody about the Group’s rules regarding the fight against corruption and verify compliance on site. Conflicts of interest and gifts have also been reviewed.
Internal or external accounting audits are in place. They are designed to ensure that books, records and accounts are not used to conceal acts of corruption or influence peddling. Checks are carried out by internal control teams or with the help of external auditors as part of the account certification audits provided for by article L. 823-9 of the French Commercial Code.
The internal audit team reports on its anti-corruption work to senior management and a report is presented to the Supervisory Board’s Audit Committee (see Sections 2.2.2 and 2.2.3).
Employees, suppliers and any third parties may report issues via a centralized system, ethicsconcerns@publicisgroupe.com. Individual issues are dealt with by the internal audit teams, reporting to the Secretary General’s office. Confidentiality is guaranteed as well as protection from the risk of reprisal.
A disciplinary system means that employees can be sanctioned by the Company if they breach the Code of Conduct. Immediate measures may be taken should suppliers contravene this anti-corruption policy
This single, centralized system, ethicsconcerns@publicisgroupe.com, is now fully operational. It enables us to respond simply and effectively to different alerts. All alerts received (post, email, etc.) are dealt with, whether they come from employees, clients, partners, suppliers or any other stakeholders. Investigations are carried out by the Internal Audit Department using the appropriate means in relation to the subject in question and ensuring strict confidentiality. Whistleblowers are protected by confidentiality and any form of retaliation is prohibited. The Internal Audit Director reports the findings of the investigations carried out to senior management and a report is presented at each meeting of the Supervisory Board’s Audit Committee.
In 2019, 66 reports were handled, 40% of which were reported from within the Company. Half of these cases were HR issues. 100% of reports were processed and went on to be investigated by internal audit with the support of internal legal experts. The Internal Audit Director reports the findings of the investigations carried out to senior management and a report is presented at each meeting of the Supervisory Board’s Audit Committee.
Ethics is a cross-functional issue, some aspects of which are covered in Section 4.2.4, relating to clients (responsible communication, personal data protection). The following are examples of some initiatives in this area carried out and monitored by the Group over the last few years:
Regarding professional self-regulation, on an international scale, the Group is still very much involved, and works with professionals and all the competent authorities of the ecosystem to advance standards and best practices. For some 80 years, the communications sector has been governed internationally by the ICC’s (International Chamber of Commerce www.iccwbo.org) Marketing Code. This ICC Code (Advertising and Marketing Communication Practice – ICC Code) sets the standard in terms of self-regulation and best practice in advertising and marketing. It covers digital communication and mobile apps. The 2018 version reiterates the founding principles: all communication must be legal, decent, honest, truthful and socially responsible. This Code sets out to be neutral in terms of technology and media and so no players are exempt. This Code sets out a clear framework for advertising aimed at children (under 12) and adolescents (between 13 and 18), takes vulnerable people into consideration and incorporates challenges associated with data collection and protection and the right to privacy:
