Universal Registration Document 2021

Chapter 2. Risks and risk management

The Internal Audit Department of Publicis Groupe works in accordance with the international professional standards issued by the IIA (The lnstitute of Internal Auditors) and, in March 2017, obtained the certification of its quality assurance and certification process by the IFACI ("Institut français de l’audit et du contrôle interne"). This certification confirms the ability of the Publicis Groupe Internal Audit Department to carry out its duties. It was renewed in March 2020 and confirmed in March 2021 and March 2022 after an annual follow-up audit.

2.2.3.2 Financial monitoring controls program

Publicis Groupe also established a program entitled Financial Monitoring Controls (FMC) consisting of a series of key controls set out by process (including in relation to CSR) and implemented across all Groupe entities.

Follow-up of the roll-out and implementation of key controls is performed at two levels using a specific IT tool (PICT/RVR):

  • a monthly self-assessment submitted by all Groupe entities helps to make them accountable for the effectiveness of their controls;
  • special teams, called FMC teams, are deployed across the various countries/regions to evaluate the effectiveness of the controls within the entities. These teams are linked to the Finance Department of each country/region as well as the Groupe’s Internal Control and Risk Management Department, which oversees them, coordinates their work, and compiles the results. These teams follow a control plan covering over 70% of the Groupe’s consolidated revenue each year.

Furthermore, a review of the key checks and controls of the corporate processes relating to financial reporting (Consolidation, Tax, M&A, etc.) is conducted on an annual basis by the Internal Audit Department.

2.2.3.3 Monitoring by the Legal Department

The Groupe’s Legal Department regularly monitors litigation-related risks within the Groupe. A summary of any significant legal disputes, as well as an estimate of their potential impacts, are presented to the Groupe’s senior management every quarter. The main legal disputes and current investigations, where relevant, are also discussed in each Audit Committee meeting.

2.2.4 Risk management framework

In conjunction with senior management, the operating management teams of the countries /regions/Solutions as well as shared service centers are heavily involved in monitoring risks associated with major contracts or business activities in emerging countries. They continually analyze the Groupe’s exposure to the loss of significant contracts, to risks of conflicts of interest and to changes in contractual clauses.

The risks relating to accounting information, the external growth policy, management of the liquidity position, exchange rates, changes in the Groupe’s debt or tax position are monitored by the Finance Department, in conjunction with senior management.

The risks associated with accounting and financial information are also subject to a detailed control, overseen by the Internal Control and Risk Management Department, on the basis of which the FMC (Financial Monitoring Controls) are defined.

The procedure for monitoring the Groupe’s risk management system was formalized beginning in 2008 with risk mapping. All of the risks that may have an impact on the Groupe’s finances, operations or image are listed. These impacts are the subject of an evaluation and a probability of occurrence is estimated for each risk identified; a level of intrinsic risk is therefore determined as well as a level of residual risk after taking into account the control system.

Thus, pursuant to article L. 225-37 of the French Commercial Code, it is stated that with regard to the Groupe’s activities, the financial risks associated with the impact of climate change have a negligible impact. However, the Groupe is mindful of measuring its environmental risks and finding solutions to reduce them (Section 4 “CSR” of the Universal Registration Document)

The risk mapping is updated on a regular basis to allow a dynamic strengthening of the risk management framework.

In 2021, the Groupe risk mapping was updated, and was presented to the Strategy and Risk Committee meetings of March 2021. The “Risk” department also carried out a risk analysis on cyber risk, studies on lessons to be learned regarding impacts of the Covid-19 crisis on our talent, the geographic distribution of our business and an update of the risk mapping related to the Duty of care, and made a significant contribution to the work carried out within the Groupe on compliance with the Sapin 2 Law.

These mappings also served as a basis, along with other items, for preparing the 2022 audit plan.