Universal Registration Document 2022

4.2.4 Duty of Care Plan

In accordance with Law no. 2017-399 of March 27, 2017 on the duty of care required for parent companies and contracting companies, transposed in article L. 225-102-4 of the French Commercial Code, Publicis Groupe has drafted and implemented a plan comprising duty of care measures for the identification of risks and prevention of serious infringements in the areas of human rights and fundamental freedoms, health, personal safety and the environment, resulting from the Company’s activities and those of the companies it directly or indirectly controls, as well as the activities of subcontractors or suppliers.

This plan includes:

• A mapping of risks for their identification, analysis and prioritization;
• Procedures for assessment of the situation of subsidiaries, subcontractors or suppliers with which the Groupe has a business relationship, with regard to risk mapping;
• Appropriate actions to mitigate risks or prevent serious harm;
• A mechanism for alerting and collecting alerts relating to the existence or occurrence of risks;
• A system for monitoring the measures implemented and assessing their effectiveness.

An update of the duty of care risk mapping was presented to the Supervisory Board by the Strategy and Risk Committee at the Board meeting of March 3, 2021. This mapping was established in 2017, and likewise, this update did not highlight any risk related to or serious violation of human rights and fundamental freedoms, the health and safety of people or the environment.

Every year since 2003, the Groupe has committed to the ten principles of the United Nations Global Compact – principles which apply to the Groupe’s employees and those of its subsidiaries, as well as to its suppliers. These principles are based on:

• the Universal Declaration of Human Rights, endorsing its article 1: all human beings are born free and equal in dignity and rights. This fundamental principle is incorporated into the Diversity, Inclusion and Anti-discrimination policy, as well as in the policy for suppliers on responsible procurement, CSR for Business Guidelines;
• the International Labour Organization (ILO) Declaration on fundamental principles and rights at work – with scrupulous concern for freedom of expression, freedom of association, and combating child and forced labor. These principles are incorporated into Talent and Human Resources, Health and safety at work and Data protection policies;
• the Rio Declaration on Environment and Development, always aiming, since 2009, to reduce the impacts of the Groupe and its subsidiaries on the environment, and offset irreducible impacts. The Net Zero Climate Policy has the same objective and is in line with the Paris Agreement;
• the United Nations Convention against corruption, with the Groupe-wide application over the last few years of the requirements of the French Sapin 2 Law, aimed at combating corruption as described in the Anti-corruption policy.

4.2.4.1 Governance and scope 

The dedicated Steering Committee on Duty of Care, set up in 2017, is made up of members of the Internal Audit, Risk Management and Internal Control Department, as well as the CSR, Procurement, Human Resources and Legal Departments. Reporting to the Groupe’s Secretary General, which is a member of the Management Board, this Committee is tasked with ensuring the implementation of a Duty of Care Plan in relation to the Company’s activities and those of all its subsidiaries or companies that it controls. The Internal Audit Department covers labor-related issues during its regular reviews (HR procedures, employee protection and information, whistleblowing system, etc.) and the CSR reporting enables to monitor indicators, particularly environmental indicators, for both subsidiaries and suppliers.

The findings of its work are presented to the Supervisory Board’s Strategy and Risk Committee.

4.2.4.2 Systems in place for the application and monitoring of the Duty of Care Plan

The Duty of Care Plan is incorporated into the Groupe’s Janus Code of Ethics. Agency CEOs are responsible for implementing local measures and the indicators are monitored at Groupe level. Measures are implemented with the involvement of Shared Service Centers (Re:Sources). Procedures for assessing the situation of subsidiaries, subcontractors or suppliers with which there is a commercial relationship are implemented. Aspects relating to the Groupe’s employees are monitored by the HR/Talent teams of the agencies and countries through the indicators mentioned and supplemented where necessary.

Aspects relating to the Groupe’s suppliers are monitored by the Groupe’s Procurement Department, in conjunction with the Groupe’s CSR Department. The CSR for Business Guidelines document presents 15 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 “P.A.S.S” platform (see Section 4.2.7).