The Groupe’s legal experts play an important role in terms of awareness and the application of anti-corruption laws and regulations. They are part of the Shared Service Centers (Re:Sources) and report to the Groupe’s Legal Department, which constantly monitors this issue. Their mission is to conduct prevention, to ensure that the processes and procedures are in place and applied, and adapted to the local market. The objective is to have the same high standards in accordance with local regulations and with Groupe ethics rules. A Chief Compliance Officer (CCO) was appointed in early 2022. Reporting to the Secretary General, the CCO will oversee the Groupe’s compliance programs.
The Anti-Bribery & Anti-Corruption policy is rolled out at all levels of the organization and is based on the principle of Zero Tolerance of any form of corruption or bribery. All employees must comply with this policy, as well as local laws or regulations. This policy includes:
This policy is updated regularly. The last update, in 2019, included helpful guidance for employees to illustrate how Groupe employees should behave and what risks to avoid. It can be accessed by the general public in the CSR Smart data section of the Groupe’s website. It provides for the principle of Zero Tolerance of any form of corruption or bribery, specifying contexts or at-risk areas and any prohibitions with which Publicis Groupe individual employees and managers must comply. It is an integral part of the Janus Code of Ethics.
In France, the anti-corruption policy is incorporated into the internal rules and, for this reason, has been the subject of the employee representative consultation procedure provided for in article L. 1321-4 of the French Labor Code.
Publicis Groupe has made an online anti-bribery & anti-corruption training program available to all employees, which everyone must complete, in order to assist them in applying the Zero Tolerance principle to any form of corruption. This training also covers how the whistleblowing system works. In 2020, an Anti-corruption Training Refresher program completed the training, reminding employees of the behavior to be adopted with third parties, on the issue of gifts and entertainment, and what to do if an employee witnesses any unethical behavior. The legal teams, at country and regional level, provide additional training to employees considered to be most exposed to this type of risk, in order to raise awareness about the Groupe's anti-corruption compliance program and ensure their proper understanding and control of compliance rules in terms of combating corruption. Employees must also complete training on Janus, the code of conduct which contains several policies on gifts, conflicts of interest, inappropriate or unethical conduct (whether with suppliers or with clients), competition issues, and unfair practices.
All employees joining the Groupe must complete an online training course during their first month in the Company. Employees are expected to complete Refresher training at least one year later.
Publicis Groupe carries out an assessment of its third parties, and carries out a specific anti-corruption review using a risk-based approach (country, business sector, track record, etc.). Publicis Groupe will not work with any third party that presents a risk of corruption or that does not agree to comply with anti-corruption laws and the Groupe’s policy in this area.
Suppliers are assessed and verified on this subject before the contract is signed. More details are provided in Section 4.2.7 of this document.
