Universal Registration Document 2022

Groupe Profile

  • for Data activities:
    • the Epsilon database, which includes 260 million American profiles (TSP – Total Source Plus), from more than 40 different sources, is refreshed every six weeks, to ensure the success of targeted actions or the activation of certain consumer Groupes. This mechanism is part of Epsilon’s responsible marketing practices in order to take into account client expectations and protect consumers. This approach makes it possible to precisely identify the target audiences and eliminate the risk of duplication and is a guarantee of quality and efficiency,
    • Truthset: Epsilon regularly calls on this external and independent data certification Company to have the quality and validity of the data used in its databases assessed by an independent third party. This provides additional security for clients; Epsilon’s data protection policies are publicly available – see https://legal.Epsilon.com/global-privacy-policies;
  • for business lines related to DBT (Digital Business Transformation), the approach is twofold around Digital for Good and Good Digital:
    • Digital for Good: the challenge is to systematically reduce anything that could limit access to products and services for some. Efficiency and broadest possible accessibility are imperative. Publicis Sapient has worked on online systems to facilitate access to Covid-19 vaccines for as many people as possible. In another program, by simplifying an application in partnership with a renewable energy Company, 1 million users were informed and then committed to a solar energy program enabling them to drastically reduce their housing costs. The Inclusion by Design principle remains central, in addition to the dual principle of transparency and accountability, particularly for projects based on deep learning or on artificial intelligence,
    • Good Digital consists of finding, for each project, solutions to reduce the impacts of digital to move towards Net Zero, through a series of Green IT audits and the implementation of eco-design in all digital projects,
    • the Center of Expertise in Accessibility created a few years ago has made it possible to train thousands of employees, and to create a kind of library open to all engineers in order to facilitate their specific tasks to write accessible code and constantly improve it. (see Section 4.2.2.2);
  • Many agencies must respond to specific compliance issues such as Healthcare agencies. Communication in this sector is regulated in many countries. This requires that our teams are trained in the local regulatory framework and sometimes led by clients who are subject to specific regulations involving a more demanding communication framework. The agency must ensure high compliance with different levels of joint validation between the operational and legal teams.
4.2.2.2 Ethics within the agencies
1) Confidentiality

Respect for the confidentiality of client data and projects is a fundamental value. It is required from 100% of employees, in addition to the obligations undertaken by employees in their employment contract with the Groupe. Teams may have access to sensitive information; they are always frequently asked to sign specific confidentiality agreements (NDA – non-disclosure agreement). Intellectual property, whatever the type of creation or output, is also protected. Experts in trademark law or copyright or database law (data base), within the legal teams, must be consulted well upstream of projects. Data protection and security specialists must also be involved in all projects to ensure that these issues are addressed strictly.

2) Intellectual property

As a creative Company, Publicis Groupe has always been committed to respecting and protecting intellectual property, an increasingly complex topic to manage in a digital and ultra-connected world. It is in this spirit that the PMX Digital team has set up an exclusive contract with WIPO (World Intellectual Property Organization) to identify and exclude sites that violate intellectual property.

3) Lobbying practices

Some assignments may involve lobbying and strategies to influence decision-makers on behalf of clients. Lobbying teams must comply with transparency criteria in relation to their clients, in such a way that their work, the objectives targeted, and the actions carried out are done so with integrity, in accordance with best practices in this area and in keeping with the laws and the Groupe’s internal procedures. The lobbying teams operate in compliance with the laws and the Groupe’s rules, particularly concerning combating conflicts of interest and anti-corruption. In accordance with legal obligations and best practices, the teams involved are identified, both in terms of the Transparency Register of the European Parliament and the European Commission, or on a country-wide basis, listed in the digital repertoire of representatives of interests managed by the High Authority for the Transparency of Public Life in France (HATVP), and in the United States where the rules of the Lobbying Disclosure Act apply, or where this relates to the FARA (Foreign Agent Registration Act), with registration in compliance with the subjects and organizations concerned.

Publicis Groupe did not lobby on its own behalf in 2022. Publicis has the intangible and historical principle of refusing to work for partisan campaigns (political parties, cults or ideological organizations). The Company does not financially or otherwise support such organizations.