Universal Registration Document 2021

Aspects relating to the Groupe’s suppliers are monitored by the Groupe’s Procurement Department, in conjunction with the Groupe’s CSR Department. The document CSR for Business Guidelines presents 12 key topics with increased requirements on several criteria. This document (accessible on the Groupe’s website) is a mandatory appendix to any contract signed between the Groupe and a supplier. Publicis Groupe uses the EcoVadis platform and invites its suppliers to be assessed on this platform; other assessments by neutral and independent third parties, dating from 12 to 18 months, are recognized by the Procurement Department. For local suppliers, mainly small and medium-sized companies, they can conduct a CSR self-assessment on the proprietary “PASS” platform (see Section 4.2.7 Responsible Procurement).

The whistleblowing system (see Section 4.2.6 below) in place within the Groupe was expanded to cover alerts relating to the duty of care and was consolidated around a single address, ethicsconcerns@publicisgroupe.com. It is designed to receive and handle internal or external alerts.

4.2.4.3 Risks monitored as part of the duty of care plan

The specific mapping of risks and serious breaches related to the duty of care is updated by the Internal Audit and Risk Department. It was presented to the Strategy and Risk Committee of the Supervisory Board on March 1, 2021. Despite the exceptional context of the year, no risk of serious harm to the three pillars of the Duty of Care Plan was identified. The Groupe’s intellectual services activities do not expose the Company to serious risks such as those related to manufacturing activities. However, three types of risks require special attention. The first relates to mental health, an increased risk in the pandemic context in which the GSO's teams have mobilized very actively to provide employees with solutions to help them. The second concerns potential risks related to the management of personal data, whether of employees or clients, in a context of increased cyberattacks. In view of the strengthened controls, the risks of exposure were very limited and well prepared. The guidelines of the Global Data Protection Office (GDPO) in terms of data protection were closely monitored by the operational teams, and the Global Security Office (GSO) has strengthened its controls at all levels. Lastly, in view of the news over the past three years and the intensity of extreme weather events that can occur simultaneously and affect some of the teams and IT infrastructures, in 2021 the Steering Committee supported a project aimed at analyzing environmental and climate risks further (see Section 4.3).

4.2.4.4 Human rights and fundamental freedoms

Human rights and fundamental freedoms must never be violated. They must be protected and respected whether in relation to employees, clients and partners, or suppliers:

• on the abolition of child labor: Publicis Groupe only hires adult employees. Short-term job shadowing (lasting a maximum of one to three weeks) may, however, be offered to minors as part of their school career or professional apprenticeship, subject to obtaining authorization from parents and in agreement with the educational institution;
• on the elimination of all forms of forced labor or modern slavery, and the fight against discrimination: the Groupe applies a Zero Tolerance policy with regard to forced labor or modern slavery, and discrimination in all its forms, against all persons. The Groupe’s employees may receive legal support in the performance of their duties, in countries with low levels of legal protection;
• on freedom of expression and freedom of association: freedom of movement, association and expression are some of the key principles recognized and protected by the Groupe. The only possible restrictions are associated with confidentiality and the safety of people, data and property, and legal requirements;
• on combating physical, sexual or moral harassment: the Groupe has a Zero Tolerance policy with regard to all forms of harassment. Behaviors or actions that may be contrary to our policy result in disciplinary measures for employees that include termination of their employment contract or potential legal action;
• in 2018, Publicis Groupe signed the Women Empowerment Principles (WEP), seven fundamental principles listed by the United Nations to act tangibly to promote women’s rights worldwide and at all levels. This commitment, along with the United Nations Global Compact, requires signatories to be transparent in their actions and results;
• on the protection of personal data: as these data are specific to each individual, this data must be protected over time and be protected from any risk of theft, intrusion or falsification.

On these five points, the Groupe asks its suppliers to comply with these standards, which are part of the CSR for Business Guidelines and are appended to the contracts signed between the Groupe and its suppliers.

Pro bono campaigns, like volunteering (see Section 4.2.9) in support of organizations or general interest causes promoting human rights (of women, men and children) and opposing all forms of exclusion and discrimination, demonstrate the long-term commitment of the Groupe, as well as its agencies and employees, to defending human rights.