Janus also includes accounting policies and procedures, applicable to the entire Groupe and all subsidiaries. This system is intended to ensure that the books, accounting documents and records are not used to conceal acts of corruption. Control tests are carried out by dedicated teams, the FMCs (Financial Monitoring Controls teams) which, during their regular reviews, also verify compliance with the Groupe’s accounting rules.
The Groupe’s anti-corruption compliance plan includes ongoing monitoring of the program by the Legal Department, and the Internal Audit teams complete audits throughout the year.
Audits are carried out by the internal audit teams or by external auditors as part of the certification audits of the financial statements provided for in article L. 823-9 of the French Commercial Code.
The Internal Audit team reports on its work to senior management and a report is presented to the Supervisory Board’s Audit Committee. The Internal Audit Department also shares its work with the Legal Department and the newly appointed Chief Compliance Officer, in order to influence decisions aimed at updating the policies, processes and procedures of the anti-corruption program.
Employees, suppliers and third parties can report violations of the anti-corruption policy, by using the ethicsconcerns@publicisgroupe.com centralized whistleblowing system described in the Reporting Concerns policy. All alerts are treated confidentially and anyone who reports a problem is protected from the risk of retaliation. All alerts are dealt with by the teams of the Internal Audit Department, or under their supervision, reporting to the Secretary General (see Section 4.2.6).
Any employee who violates the anti-bribery & anti-corruption policy may be subject to disciplinary action, the result of which may be severe penalties up to and including dismissal. Immediate measures may be taken should suppliers contravene this policy.
Employees, suppliers and third parties may report a violation of the law or company policies on fraud, corruption, harassment, discrimination or any other ethics concerns, as stated in the Janus Code of Ethics and the Reporting Concerns or so-called “Whistleblowing” policy. This system is accessible to all employees and third parties and is publicly available in the CSR Smart data section of the Groupe’s corporate website.
The ethicsconcerns@publicisgroupe.com system makes it possible to respond to all alerts, whether internal or external. All alerts received are dealt with, whether they come from employees, clients, partners, suppliers or any other stakeholders, or if raised anonymously. Investigations are carried out by the Internal Audit Department using the appropriate means in relation to the subject in question and ensuring strict confidentiality. Whistleblower communications are protected by confidentiality and any form of retaliation is prohibited.
In 2021, 38 reports were handled, 45% of which were reported from within the Company.42% of cases concerned HR issues. 100% of reports were processed and went on to be investigated by internal audit with the support of internal legal experts. The Internal Audit Director reports the findings of the investigations carried out to senior management and a report is presented at each meeting of the Supervisory Board’s Audit Committee.
Standardization of the various internal processes over the last two years has enabled the Groupe’s Procurement Department to systematize its compliance programme, based on five steps, intended to assess the business relationship with the supplier:
