The Groupe complies with the provisions of the French law known as “Sapin 2”, article 17 II.1°. The Groupe has implemented a compliance program as provided for by law, including the code of conduct (Janus) and the anti-corruption policy, illustrating acts and behaviors relating to corruption or influence peddling that are prohibited. The Groupe is also in compliance with the other anti-corruption laws applicable where we operate.
The anti-corruption compliance program includes:
The Groupe’s Legal and Compliance 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 Compliance Office and Groupe Legal Department, which constantly monitors the program. Their mission is to prevent bribery and corruption and to help ensure compliance processes and procedures are in place, applied and adapted to local markets. The aim is to maintain the high standards that comply with current applicable regulations and the Groupe ethics rules and policies. The Legal and Compliance experts who support the implementation and monitoring of the anti-corruption compliance program report into the Groupe’s Chief Compliance Officer (CCO). Reporting to the Groupe Secretary General, the CCO oversees the Groupe’s compliance programs, including the anti-corruption compliance program.
The Anti-Bribery & Anti-Corruption Policy is rolled out at all levels of the organization and is based on the principle of zero tolerance for any form of bribery or corruption. All employees must comply with this Policy, as well as with all applicable anti-corruption laws. This Policy includes:
This Policy is regularly reviewed by the Compliance Department to ensure it is up-to-date and effective. The Policy was last updated in early 2023 to include additional helpful guidance, following the 2022 Corruption Risk Map exercise, clarified that the Policy also applies to business partners, and added a reminder on Conflicts of Interests.
The Anti-Corruption Policy is accessible to all employees in the Anti-Bribery & Anti-Corruption chapter in Janus. 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. It can be accessed by the general public in the CSR Smart data section of the Groupe’s website.
Publicis Groupe has made an online anti-bribery & anti-corruption training program available to all employees. The online training program includes a full anti-corruption training course: it is 25 minutes in length and is designed to guide them in prevention and detection of corruption risk and in applying the Zero Tolerance principle to any form of corruption. This training also covers how the whistleblowing system works. Specifically, the course highlights the rules around giving and receiving gifts and entertainment, working with public officials, and engaging third party representatives. The full course is mandatory for all employees and new joiners are invited to complete the course within one month of joining the Groupe. For all employees who have completed the full course, an anti-corruption refresher training, called the “Refresher”, has been made available to all employees and is to be completed one-year after the full course. This program enhances 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. In 2022, the Groupe released an online training course on the Groupe’s Reporting Concerns Policy, and how to raise a good faith concern about unethical behavior in the workplace. It reminded employees of the importance of raising their voice when they witness unethical behavior, how to report good faith concerns, including anonymously, if preferred, and how the Groupe treats concerns (promptly, confidentially, and without retaliation). In-person anti-corruption training is also available to employees with a heightened risk of exposure to corruption. Legal teams at Groupe, country and regional levels host training sessions all year to targeted employee audiences and aim to raise awareness and strengthen compliance with the Groupe’s rules around preventing and detecting corruption.
