2020 Annual Financial Report

The ethicsconcerns@publicisgroupe.com system makes it possible to respond to all alerts, whether internal or external. All alerts received 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. Whistleblower communications are protected by confidentiality and any form of retaliation is prohibited.

In 2020, 56 reports were handled, 32% of which were reported from within the Company. 41% of cases concern 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.

4.4.5   Audits and Certifications

Communications industries are subject to different formal frameworks. The Groupe’s agencies are sometimes audited by clients on different issues. In the United States, in response to a request from the Association of National Advertisers (ANA) focusing on issues of audience reliability, all the audits conducted at Publicis Media failed to show any anomalies, thus making the media solutions offered to clients even more credible.

The main certifications in place in agencies are:

• ISO certifications; 26.3% of headcount is covered by the various ISO certifications; the majority of these cover agencies in India and the United States;

• professional certifications; in some countries, these are required for certain activities, for example, with the CENP in Brazil or the CAANR in New Zealand;
• technological certifications, which are widespread and cover different types of technical standards.

As well as:

• industry qualifications related to certain tightly controlled business sectors, such as healthcare for Publicis Health agencies, in the United States, France and the United Kingdom: employees are trained in local regulatory frameworks and every campaign undergoes a Compliance review;
• professional accreditations enable checks and audits to be conducted on behalf of clients, as is the case with Publicis Communications in the United States which conducts audits requested by clients on different aspects such as supplier diversity.

4.4.6   Compliance

Compliance matters are monitored by the Groupe’s Legal Department under the responsibility of the Secretary General, with the support of the local teams in all countries.

In relation to the GRI guidelines:

• Publicis Groupe, whose core activities involve the provision of intellectual services, has not recorded any incidents involving child labor or forced or compulsory labor, nor incidents relating to the violation of the rights of native populations, nor human rights grievances;
• Publicis Groupe has not experienced any incidents of non-compliance with voluntary rules and codes concerning: impacts on consumer health and safety; information about its products and services; the provision and use of its services;
• Publicis Groupe has had no complaints filed against it for invasion of privacy or loss of client-related data;
• as happens every year, a very small number of agencies (fewer than ten) recorded incidents of non-compliance with regulations and voluntary codes relating to communications, more often than not in the form of notices or notifications issued by regulatory or self-regulated bodies, on each occasion giving rise to immediate modifications;
• Publicis Groupe has not had to fight any legal actions for infringement of anti-trust laws, anti-competitive behavior or monopolistic practices, or corruption.

Regarding article R. 225-105 and supplementary information required by other French legal texts, the environmental impacts are dealt with in the section below. However, some indicators do not apply to Publicis Groupe, given the nature of the service-based and intellectual activities, namely:

• the resources dedicated to preventing environmental risks and pollution. Given the insignificant level of these types of risk, the Groupe does not envisage writing any provisions and guarantees for environmental risks or risks associated with climate change;
• the consideration of noise pollution and other forms of activity-specific pollution;
• measures taken to prevent, reduce or repair air, water and soil pollution (including land use) affecting the environment.