Universal Registration Document 2022

4.2.7 Responsible procurement

4.2.7.1 Due Diligence 

In 2022, and for the last three years, the Groupe Procurement Department has extended its supplier compliance program in order to have more precise monitoring. The scope of this risk analysis and compliance program is based on five pillars:

1. Risk analysis: the Procurement Department teams carry out this part, which covers a wide range of subjects, such as the financial health of the Company or supplier reputation issues;
2. Anti-corruption: the Groupe’s legal teams apply the risk assessment grid, in order to assess whether suppliers are in compliance with local laws and the Groupe standards set out in the anti-corruption policy, and with which they must comply without exception;
3. Data protection: under the application of the GDPR (General Data Protection Regulation) and other regulations, suppliers are required to comply with the Groupe’s DPA (Data Processing Addendum). Critical reviews are carried out by the GDPO (Global Data Privacy Office) and depending on the level of data protection risks identified, the processes put in place are analyzed to ensure the proper application of mitigation measures;
4. Security of IT systems: Global Security Office (GSO) teams conduct a technical review combined with tests (due diligence) on the security of suppliers’ systems in order to verify their compliance and their security. They validate the service continuity plans proposed by suppliers;
5. CSR, social and environmental impacts: the CSR component is addressed either by external assessments for the Groupe’s strategic suppliers, or for critical suppliers, by a CSR self-assessment on the Groupe’s P.A.S.S (Publicis Groupe Providers’ Platform for a self-Assessment for a Sustainable Supply chain) platform. In the context of calls for tenders initiated by the Groupe Procurement Department, CSR assessments account for 20% of the final score awarded to the supplier’s proposal.

Two dimensions are treated in specific ways: suppliers’ diversity, in order to better identify them and work with a greater number of them, and the climate commitments that are subject to ad hoc monitoring.

In terms of subcontracting, the agencies endeavor to anticipate as best they can their clients’ major constraints, notably concerning the time needed to carry out certain projects during peak activity periods. In all countries, the Groupe ensures that all suppliers are treated fairly and paid promptly. All employees negotiating with suppliers must respect the rules of the Janus Code of Ethics and act in a professional and rigorous manner, free from any conflicts of interest.

The policy CSR for Business Guidelines is explicit and demanding on the three aspects related to the application of the Duty of Care Law: human rights and fundamental freedoms, health and safety of people, environmental impacts. This 15-point policy reflects the continuous work carried out between the Groupe’s Procurement and CSR Departments, supported by regular training sessions on regulatory issues, market developments to be anticipated, the sharing of best practices and discussions on indicators. The Groupe’s Procurement team is based in the Groupe’s three main regions: Americas, Europe and APAC. The Groupe and agencies’ procurement policy is proactive in terms of eco-responsible, eco-designed products from the circular economy or that have been responsibly sourced or have a recognized environmental certification. This policy is subject to an annual review.

This CSR for Business Guidelines policy is included as an appendix to all calls for tenders and is part of the contractual clauses signed between Publicis Groupe and its suppliers. This document is publicly available in CSR Smart data and is communicated to suppliers when contracts are renewed. Non-compliance with any one of these 15 points is a non-selection criterion.