2020 Annual Financial Report

Chapter 4 : Corporate social responsibility – non-financial performance

4.2.2.4  Professional approaches of the various business lines

Although the communications industry has a framework of rules and sometimes laws too, the profession has always promoted professional self-regulatory mechanisms to ensure that the ethics of advertising content are respected. The Groupe and its agencies work hand in hand with various national bodies such as ASRC (Advertising and Self-Regulation Council) in the United States, ASA (Advertising Standards Authority) in the United Kingdom, ARPP (Autorité de régulation professionnelle de la publicité) in France, EASA (European Advertising Standards Alliance) in Europe, and the ASC (Advertising Standards Council) in India.

This principle of responsibility is constantly defended by the Groupe and has made it possible to establish standards banning certain types of formats. The Groupe has always defended people’s right to have control over their data. This principle guides technology choices and solutions offered to clients who need to have control over their data, just like end users who need to be able to access, correct or delete their own data, thus aligning themselves with the rules of the GDPR (see Section 4.3.1.1). It is also part of the work of an organization like the IAB (International Advertising Bureau) in which the Groupe participates. In the digital world, the Groupe’s agencies attach particular importance to the fact that digital advertising must not be intrusive, regardless of the channel used.

The Groupe is very active in many countries. This includes the United Kingdom, where the Groupe’s participation in the industry initiative “actions not words” in favor of the fight against racism and inequalities, or France, with the active participation of the Groupe in the General Meeting on communication, inviting the entire industry to get involved in the ecological and social transition.

4.2.3    Ethical principles applying to all Groupe agencies

The ethical principles applying to all Groupe agencies involve two main aspects. On the one hand, compliance with the internal Code of Ethics, Janus, which applies to all employees, and which sets out a clear framework for managers on how to operate in a number of areas (see Section 3.1.5) whatever the agency’s business. On the other, there are ethical principles that apply to specific businesses or activities. One classic example of this is compliance issues in health agencies. Communication in this sector is regulated in many countries. This means that the teams in our agencies receive training in the local regulatory framework, as well training from their clients who may have more specific communication frameworks.

For all output, whatever the client’s business sector, the compliance review carried out with legal managers is part of the internal validation process. Compliance teams on both the agency side and the client-side work closely upstream of campaigns.

4.2.3.1   Lobbying practices

Some assignments may involve lobbying and strategies to influence decision makers on behalf of clients. Lobbying teams must comply with transparency criteria in relation to their clients, in such a way that their work, the objectives targeted, and the actions carried out are done so with integrity, in accordance with best practices in this area and in keeping with the Groupe’s internal procedures. In accordance with legal obligations and best practices, the teams involved are clearly identified, both in terms of the Transparency Register of the European Parliament and the European Commission, or on a country-wide basis, listed in the digital repertoire of representatives of interests managed by the High Authority for the Transparency of Public Life in France (HATVP), and in the United States where the rules of the Lobbying Disclosure Act apply or where this relates to the FARA (Foreign Agent Registration Act), with registration in compliance with the subjects and organizations concerned.

Publicis Groupe did not do any lobbying on its own behalf in 2020.

4.2.3.2   Confidentiality

Respect for the confidentiality of client data and projects is a fundamental value and is required from 100% of employees, in addition to the obligations undertaken by employees in their employment contract with the Groupe. Teams may have access to sensitive information; they are frequently asked to sign specific confidentiality agreements (NDA – non-disclosure agreement). Intellectual property, whatever the type of creation or output, is also protected. Experts in trademarks or copyright or database rights, provide input in the very early stages of a project, in all countries. Data protection specialists are involved in all projects to ensure that these issues are properly understood. (See also Section 4.3.1).