This policy is updated regularly. It can be accessed by the general public in the CSR Smart data section of the Groupe’s website. It provides for the principle of Zero Tolerance of any form of corruption or bribery, specifying contexts or at-risk areas and any prohibitions with which Publicis Groupe individual employees and managers must comply. It forms part of the Janus Code of Ethics.
In France, the anti-corruption policy is incorporated into the internal rules and, for this reason, has been the subject of the employee representative consultation procedure provided for in article L. 1321-4 of the French Labor Code.
Publicis Groupe has made an online anti-bribery & anti-corruption training program available to all employees, which everyone must complete, in order to assist them in applying the Zero Tolerance principle to any form of corruption. This training also covers how the whistleblowing system works. In 2020, an Anti-corruption Training Refresher program completed the training, reminding employees of the behavior to be adopted with third parties, on the issue of gifts and entertainment, and what to do if an employee witnesses any unethical behavior. The legal teams provide additional training to employees considered to be most exposed to this type of risk, in order to ensure their understanding of compliance rules in terms of combating corruption. Employees must also complete training on Janus, the code of conduct which contains several policies on gifts, conflicts of interest, inappropriate or unethical conduct (whether with suppliers or with clients), competition issues, and unfair practices.
100% of employees joining the Groupe must complete an online training course during their first month in the Company. Every year, all employees receive Refresher training.
Third-party assessment
Publicis Groupe carries out an assessment of its third parties, and carries out a specific anti-corruption review using a risk map (country, business sector, track record, etc.). Publicis Groupe will not work with any third party that presents a risk of corruption or that does not agree to comply with anti-corruption laws and the Groupe’s policy in this area.
Suppliers are assessed and verified on this subject before the contract is signed. More details are provided in Section 4.2.5 of this document.
Janus also includes accounting policies and procedures, as well as a framework applicable to the entire Groupe and all subsidiaries. This system is intended to ensure that the books, accounting documents and records are not used to conceal acts of corruption. Control tests are carried out by dedicated teams, the FMCs (Financial Monitoring Controls teams) which, during their regular reviews, also verify compliance with the Groupe’s accounting rules.
The Groupe’s anti-corruption compliance plan includes ongoing monitoring of the program by the Legal Department, and the Internal Audit teams carry out checks throughout the year.
Audits are carried out by the internal audit teams or by external auditors as part of the certification audits of the financial statements provided for in 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 of this document). The Internal Audit Department also reports on its work to the Legal Department, in order to modify, if necessary, the policies and procedures of the anti-corruption program.
Employees, suppliers and third parties can report violations of the anti-corruption policy, by using the ethicsconcerns@publicisgroupe.com centralized whistleblowing system described in the Reporting Concerns policy. All alerts are treated confidentially and anyone who reports a problem is protected from the risk of retaliation. All alerts are dealt with by the Internal Audit Department, reporting to the Secretary General.
Any employee who violates the anti-bribery & anti-corruption policy may be subject to disciplinary action, the result of which may be severe penalties up to and including dismissal. Immediate measures may be taken should suppliers contravene this policy.
Groupe employees may report a problem in terms of violation of the law or company policies on fraud, corruption, harassment, discrimination or any other ethics issue, as stated in the Janus Code of Ethics and the Reporting Concerns or so-called “Whistleblowing” policy. This system is accessible to all employees and third parties. It is updated regularly and is publicly available in the CSR Smart data section of the Groupe’s corporate website.
