The declaration of non-financial performance examined relates to the financial year ended December 31, 2020.
Request, Responsibilities and Independence
Following the request made to us by Publicis Groupe and pursuant to the provisions of article L. 225-102-1 of the French Commercial Code, we have verified the declaration of
non-financial performance (DNFP) relating to the financial year ended December 31, 2020 published in the Universal Registration Document of Publicis Groupe, as an independent third party accredited by the Cofrac under no. 3-1341 (list of locations and scope available on www.cofrac.fr).
It is the responsibility of the Management Board of Publicis Groupe to prepare and publish a DNFP with reference to articles L. 225-102-1, R. 225-105 and R. 225-105-1 of the French Commercial Code. The DNFP was prepared in accordance with Publicis Groupe’s reporting procedures, hereinafter referred to as “the reporting procedures”. The DNFP will be available on the Company’s website together with a summary of the “reporting procedures”.
It is our responsibility to audit the DNFP so that we can formulate a reasoned opinion regarding:
- compliance of the DNFP with the provisions of article R. 225-105 of the French Commercial Code;
- the true nature of the information provided in accordance with paragraph 3 of I and II of article R. 225-105.
We conducted the DNFP audit work in an impartial and independent manner, in accordance with the professional practices of the independent third party, based notably on the principles of AA1000 and in application of the Code of Ethics applied by all parties involved in Bureau Veritas’ work.
Nature and scope of the audit work
In order to issue a reasoned opinion on the compliance of the DNFP and a reasoned opinion on the fairness of the information provided, we performed our audit work in accordance with articles A. 225-1 to A. 225-4 of the French Commercial Code and with our internal methodology, for the verification of the DNFP, in particular:
- we have taken note of the scope of consolidation to be considered for the preparation of the DNFP, as specified in article L. 233-16 of the French Commercial Code. We checked that the DNFP covers all the companies included in the scope of consolidation specified in the DNFP;
- we have gathered the information required for an understanding of the Company’s activities, the context in which the Company operates, and the social and environmental consequences of its activities and the effects of these activities on respect for human rights and the fight against corruption and tax evasion.
We have read the content of the DNFP and verified that it incorporates the elements of article R. 225-105 of the French Commercial Code:
- presentation of the Company’s business model,
- the description of the main risks related to the Company’s activity, for each category of information mentioned in III of article L. 225-102-1, including, where relevant and proportionate, the risks created by its business relationships, products or services, as well as the policies applied by the Company, where applicable, the due diligence procedures implemented to prevent, identify and mitigate the occurrence of the risks identified,
- the outcome of these policies, including key performance indicators.
In detail, our audit work was as follows:
- we examined the Company’s system for reviewing the consequences of its activities as listed in III of article L. 225-102-1, identifying and prioritizing the related risks;
- we ensured that the DNFP covers all the categories of information provided for in this article or includes a clear and reasoned explanation of the reasons justifying the absence of a policy concerning one or more of these risks;
- we verified that the DNFP presents, where relevant with regard to the main risks or policies presented, the information provided for in II of article R. 225-105;
- we ensured that the Company has put in place collection processes aimed at ensuring the comprehensiveness and consistency of the information mentioned in the DNFP. We examined the “reporting procedures” with regard to their relevance, reliability, understandability, completeness and neutrality and, where applicable, taking into account good professional practices derived from industry guidelines;
- we identified the persons within the Company who are in charge of all or part of the reporting process and we conducted interviews with some of these persons;
- we inquired about the existence of internal control and risk management procedures set up by the Company;
- we assessed, on a sample basis, the implementation of the “reporting procedures”, in particular the processes for collecting, compiling, processing and auditing information;
- for the quantitative data(1) that we considered to be the most important, we:
