Universal Registration Document 2021

4.2.4 Duty of Care Plan

In accordance with Act no. 2017-399 of March 27, 2017 on the duty of care required for parent companies and contracting companies, transposed in Article L. 225-102-4 of the French Commercial Code, Publicis Groupe has drafted and implemented a plan comprising duty of care measures for the identification of risks and prevention of serious infringements in the areas of human rights and fundamental freedoms, health, personal safety and the environment, resulting from the Company’s activities and those of the companies it directly or indirectly controls, as well as the activities of sub-contractors or suppliers.

This plan includes:

• a mapping of risks for their identification, analysis and prioritization;
• procedures for regular assessment of the situation of subsidiaries, subcontractors or suppliers with which the Groupe has a business relationship, with regard to risk mapping;
• appropriate actions to mitigate risks or prevent serious harm;
• a mechanism for alerting and collecting alerts relating to the existence or occurrence of risks with the employee representative organizations;
• a system for monitoring the measures implemented and assessing their effectiveness.

An update of the duty of care risk mapping was presented to the Supervisory Board by the Strategy and Risk Committee at the Board meeting of March 3, 2021. This mapping was established in 2017, and likewise, this update did not detect any risk related to or serious violation of human rights and fundamental freedoms, the health and safety of people or the environment.

Every year since 2003, the Groupe has committed to the 10 principles of the United Nations Global Compact – principles which apply to the Groupe’s employees and those of its subsidiaries, as well as to its suppliers. These principles are based on:

• the Universal Declaration of Human Rights, endorsing its article 1: all human beings are born free and equal in dignity and rights. This fundamental principle is incorporated into the Diversity, Inclusion and Anti-discrimination policy, as well as in the policy for suppliers on responsible purchasing, CSR for Business Guidelines;
• the International Labor Organization (ILO) Declaration on fundamental principles and rights at work – with scrupulous concern for freedom of expression, freedom of association, and combating child and forced labor. These principles are incorporated into Talent and Human Resources, Health and Safety at work and data protection policies;
• the Rio Declaration on Environment and Development, always aiming, since 2009, to reduce the impacts of the Groupe and its subsidiaries on the environment, and offset irreducible impacts. The Net Zero Climate Policy has the same objective and is in line with the Paris Agreement;
• United Nations Global Compact are incorporated into several sections of the Janus Code of Ethics, in particular, HR & General Policies, CSR Framework and CSR Guidelines for Business. Governance and scope

4.2.4.1 Governance and scope

The dedicated Steering Committee on Duty of Care, set up in 2017, is made up of members of the Internal Audit and Risk Management Department, as well as the CSR, Procurement, Human Resources and Legal Departments. Reporting to the Groupe’s Secretary General, which is a member of the Management Board, this Committee is tasked with ensuring the implementation of a Duty of Care Plan in relation to the Company’s activities and those of all its subsidiaries or companies that it controls. Internal Audit covers labor-related issues during its regular reviews (HR procedures, employee protection and information, whistleblowing system, etc.) and the CSR reporting enables to monitor indicators, particularly environmental indicators, for both subsidiaries and suppliers.

The findings of its work are presented to the Supervisory Board’s Strategy and Risk Committee.

4.2.4.2 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 HR/Talent teams via the indicators mentioned, supplemented, where necessary.