Universal Registration Document 2021

Chapter 4. Corporate social responsibility – Non-financial performance

  •  for data activities:
    • the Epsilon database, which includes 260 million American profiles (TSP – Total Source Plus), with more than 40 different sources, is refreshed every six weeks, to ensure the success of targeted actions or the activation of certain consumer groups. This mechanism eliminates the risk of duplication and ensures both quality and efficiency;
    • Truthset: Epsilon regularly calls on this external and independent data certification company to have the quality and validity of the data used in its databases assessed by an independent third party. This provides additional security for clients;
  • for jobs related to DBT (Digital Business Transformation), two aspects are subject to a close review for projects that use algorithms and deep learning or artificial intelligence (AI): on the one hand, the principle “Inclusion by design”, requiring different possible biases to be taken into account from the start of the project in order to design a platform or application that works well for all users and that does not hurt anyone (Never Harm Anyone); on the other hand, the double principle of transparency and responsibility, in relation to any difficulties encountered in order to learn from mistakes.

P.R.I.S.M.S (Publicis Groupe Program for Responsible, Inclusive and Sustainable Marketing Standards) addresses the material and operational challenges of business lines and goes beyond the first stages of legal compliance. On this point, for all work product, regardless of the client’s sector of activity, a compliance review is conducted upstream with the legal teams, in order to validate a set of prerequisites, whether these are the various legal local compliance issues, as well as the compliance with charters and/or codes of best practice issued by the client’s sector and/or by the client itself.

Some entities may have specific compliance issues, such as the health agencies. Communication in this sector is regulated in many countries. This means that our teams receive training in the local regulatory framework and sometimes training from their clients in a complementary manner, as they may themselves have a more demanding communication framework. The agency must ensure high compliance with different levels of joint validation between the operational and legal teams.

4.2.2.2 Ethics within the agencies
1) Confidentiality

Respect for the confidentiality of client data and projects is a fundamental value. It 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 always 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 trademark law or copyright or database law (data base), within the legal teams, are involved well upstream of projects. Data protection and security specialists are also involved in all projects to ensure that these issues are addressed strictly.

2) Intellectual property

As a creative company, Publicis Groupe has always been committed to respecting and protecting intellectual property, an increasingly complex topic to manage in a digital and ultra-connected world. It is in this spirit that the PMX Digital team has set up an exclusive contract with WIPO (World Intellectual Property Organization) to identify and exclude sites that violate intellectual property.

3) 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. The lobbying teams comply with the laws and the Groupe’s rules, particularly in terms of combating conflicts of interest and corruption. 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 2021. Publicis has the intangible and historical principle of refusing to work for partisan campaigns (political parties, sects or ideological organizations) and as such, does not support organizations of this type financially or in any other form.

4) Commitment to professional organizations

Publicis Groupe plays an active role within professional organizations in all countries and its commitment is always publicly identifiable on the websites of these organizations: for example, the IAB (Interactive Advertising Bureau) and its representations in several countries, as well as in the United States, with the 4As (American Association for Advertising Agencies); in France within the AACC (Association of Communication Consulting Agencies), UDECAM (Union of Consulting Companies and Media Purchasing). Outside the United States, including 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 in France the Groupe’s active participation in the General Communications Meetings inviting the entire sector to get involved in the ecological and social transition, and to put tools and indicators in place to move the sector.