The Groupe Compliance Department regularly monitors attendance rates to both the online and in-person training programs and ensures the materials are effective at communicating the Groupe’s commitment to ethics. In 2022, 85% of employees had received training.
Publicis Groupe completes an assessment of its third parties and performs anti-corruption-specific due diligence using a risk-based approach. Publicis Groupe will not work with any third party that presents a risk of corruption or that does not agree to comply with anti-corruption laws and the Groupe’s anti-corruption policy. Suppliers are assessed and verified in this regard before the contract is signed. For further detail regarding the Groupe’s third party assessment efforts in procurement (see Section 4.2.7 of this document).
Janus also includes an accounting policies and procedures framework applicable to the Groupe and all of its subsidiaries. These accounting policies and procedures are intended to ensure that the books, records and accounts are not used to conceal acts of corruption. Control tests are carried out by dedicated teams, the FMCs (Financial Monitoring Controls teams) periodically to ensure compliance with the Groupe’s accounting rules.
The Groupe’s anti-corruption compliance plan includes ongoing monitoring of the program by the Compliance Department, and the Internal Audit teams complete audits throughout the year. The Internal Audit, Risk Management and Control Department interacts regularly with these two departments in order to optimize audit and internal control practices and contribute to the anti-corruption program.
Audits are carried out by Internal Audit 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.
Internal Audit reports on its work, including its anti-corruption work audit program, 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 Compliance Department, to influence decisions aimed at updating the policies, processes and procedures of the anti-corruption compliance program.
Employees, suppliers and third parties can report violations of the anti-corruption policy or applicable anti-corruption law by using the ethicsconcerns@publicisgroupe.com centralized whistleblowing system described in the Reporting Concerns policy. Alerts can be made anonymously and all alerts are treated promptly and confidentially. The Groupe will not retaliate against any employee who raises a good faith concern. All alerts are dealt with by the teams of the Internal Audit Department, reporting to the office of 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 all other parties may report any concern related to a potential violation of laws or Company policies on fraud, corruption, harassment, discrimination or any other ethics concerns, as stated in the Janus Code of Ethics Reporting Concerns or so-called “Whistleblowing” policy. This system is accessible to all employees and is publicly available in the CSR Smart data section of the Groupe’s corporate website.
The dedicated address ethicsconcerns@publicisgroupe.com makes it possible to respond to all types of alerts, whether internal or external. All whistleblowing alerts received are processed even those sent anonymously. They are dealt with by the Internal Audit, Risk Management and Control Department or the Legal Department under the supervision of the Secretary General. Investigations are carried out by the Internal Audit Department or by a lawyer, 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.
