2020 Annual Financial Report

4.4.2.2  Systems in place for the application and monitoring of the Duty of Care Plan

The Groupe’s Duty of Care Plan is forwarded to all subsidiaries. It is incorporated into the Groupe’s Janus Code of Ethics. Agency CEOs are responsible for implementing local measures and the indicators are monitored at Groupe level.

Measures are implemented with the involvement of Shared Service Centers (Re:Sources). Procedures for the regular assessment of subsidiaries, subcontractors or suppliers with which the Company has an established business relationship, are regularly put in place.

All other aspects relating to the Groupe’s employees are monitored by agency and country Talent and Human Resources teams via the indicators mentioned, supplemented, where necessary.

Aspects relating to the Groupe’s suppliers are monitored by the Groupe’s Procurement Department, in conjunction with the Groupe’s CSR Department. The document CSR for Business Guidelines presents 12 key topics with increased requirements on several criteria. This document (accessible on the Groupe’s website) is a mandatory appendix to any contract signed between the Groupe and a supplier. Publicis Groupe uses the EcoVadis platform and invites its suppliers to be assessed on this platform; other assessments by neutral and independent third parties, dating back less than 12 months, are recognized by the Procurement Department. For local suppliers, mainly small and medium-sized companies, they must now carry out a CSR self-assessment on the Groupe’s proprietary P.A.S.S. platform. (see Section 4.2.5 Responsible Procurement).

The whistleblowing system, (Whistleblowing, see Section 4.4.4 below) in place within the Groupe, was expanded to cover alerts relating to the duty of care and was consolidated around a single address, ethicsconcerns@publicisgroupe.com, designed to receive and handle internal or external claims.

4.4.2.3  Risks monitored as part of the Duty of Care Plan

In 2020, the specific mapping of risks and serious breaches related to the duty of care was updated by the Internal Audit and Risk Department. It was presented to the Strategy and Risk Committee of the Supervisory Board. Despite the exceptional context of the year, no risk of serious harm to the three pillars of the Duty of Care Plan was identified. The Groupe’s intellectual services activities do not expose the Company to serious risks such as those related to manufacturing activities. However, two types of risks emerged as the main concerns. The first relates to mental health, a risk that has increased in the context of the Covid-19 pandemic, teams have been very active in providing employees with the solutions best able to assist them. The second concerns potential risks related to the management of personal data, whether of employees or clients, in a context of increased cyberattacks. In view of the strengthened controls, the risks of exposure were very limited and well prepared. The guidelines of the Global Data Protection Office (GDPO) in terms of data protection were closely monitored by the operational teams, and the Global Security Office (GSO) has strengthened its controls at all levels.

4.4.2.4  Human rights and fundamental freedoms

Human rights and fundamental freedoms must never be violated. They must be protected and respected whether in relation to employees, clients and partners, or suppliers. Publicis Groupe has put systems in place to prevent serious violations of human rights and fundamental freedoms:

• on the abolition of child labor; Publicis Groupe only hires adult employees. Short-term job shadowing (lasting a maximum of one to three weeks) may, however, be offered to minors as part of their school career or professional apprenticeship, subject to obtaining authorization from parents and in agreement with the educational institution;
• on the elimination of all forms of forced labor or modern slavery, and the fight against discrimination; the Groupe applies a Zero Tolerance policy with regard to forced labor or modern slavery, and discrimination in all its forms, against both women and men. The Groupe’s employees may receive legal support in the performance of their duties, in countries with low levels of legal protection;
• on freedom of expression and freedom of association. Freedom of movement, association and expression are some of the key principles recognized by the Groupe with regard to employees, both women and men. The only possible restrictions are associated with confidentiality and the safety of people, data and property, and legal requirements;
• on combating physical, sexual or moral harassment; the Groupe has a Zero Tolerance policy with regard to all forms of harassment. Behaviors or actions that may be contrary to our policy result in disciplinary measures for employees that include termination of their employment contract or potential legal action.
• In 2018, Publicis Groupe signed up to the Women Empowerment Principles (WEP), seven fundamental principles listed by the United Nations to act tangibly to promote women’s rights worldwide and at all levels. This commitment, along with the United Nations Global Compact, requires signatories to be transparent in their actions and results. The Groupe has also chosen to follow the United Nations’ Sustainable Development Goals (SDGs – see Section 4.8) since 2015, concentrating on 10 of these to measure its contribution and positive impacts;
• on the protection of personal data; as these data are specific to each individual, this data must be protected over time and be protected from any risk of theft, intrusion or falsification. Data protection procedures managed by the Groupe Data Protection Office, and system security procedures managed by the Groupe Security Office have proven to be very effective.