Universal Registration Document 2023

4. Corporate Social Responsibility Non-Financial Performance - AFR

  •  The Groupe’s CSR/ESG Department reports to the Groupe’s Secretary General; this team is in charge of preparing and rolling out the ESG strategy, Groupe projects and policies as well as non‑financial reporting. The Janus Code of Conduct and Ethics incorporates   into ESG policies. It is based on the CSR Steering Committee, in place since 2015, which brings together the corporate departments: Legal and Compliance, Finance and Information Systems, Human Resources Operations, Groupe Procurement, Risks, Internal Control, Internal Audit, Shared Services/Re:Sources (IT, Real Estate, etc.). The managers of the countries or activities are involved in the work in order to align with the challenges of clients. In 2023, work focused on the ESG risk mapping, the double materiality analysis, the review of the gaps between the CSRD & ESRS compared to the DNFP, the data points already collected as part of the GRI, and the preparation of the 2024 reporting.
  • The CSR Department leads several internal forums for sharing experience and cooperation that have been set up, such as the DEI Council, which brings together the Diversity managers every two months, or the Climate Crew, which brings together the teams in charge of actions to reduce environmental impact every two months. It is also working with the various business lines in several countries to identify indicators specific to the activities around the challenges of responsible marketing.
  • The Risk Management team developed the ESG risk mapping in order to use a common base and methodology with the mapping of the Groupe’s majorrisks and to ensure consistency with the double materiality exercise. Supported by the FMC team (Financial Monitoring Controls) (see Section 2.2.3.2), it supports the CSR Department in structuring an ESG control framework, built on the basis of controls that have existed for several years, and by integrating the new elements of the CSRD and ESRS. Risk Management also took part in the work on double materiality.
  • The Internal Audit Department already includes certain CSR/ESG topics in its work program, such as those relating to Talent, compliance issues in terms of personal data, and IT systems security.
  • In agencies and countries, the operational deployment of CSR actions is conducted under the responsibility of local management, and priority actions are implemented based on the topic by their dedicated CSR or Sustainability teams, and with dedicated Talent, HR and Diversity, Equity and Inclusion teams, not to mention the local Re:Sources teams, for the support functions in the shared services centers, which collect environmental data. It is important to highlight the very large number of employees volunteering to initiate new CSR/ESG initiatives and innovate in their daily professional practices.

Materiality of ESG issues and stakeholder consultation

ESG Risk Mapping

Historically, ESG risks have been included in the Groupe’s major risk map (see Chapter 2 of this document), in particular risks relating to Talent and social issues, but also risks related to ethics, personal data and data security. These risks are also analyzed and monitored as part of the application of the Duty of Care Law (see Section 4.3.10). The Groupe's major risk trends are monitored by the Strategy and Risk Committee and the Audit Committee of the Supervisory Board. Topics are treated in‑depth as part of the work of the ESG Committee and the monitoring of the Company’s three main ESG priorities.

The entry into force of the CSRD was an opportunity for in‑depth work, carried out in 2023, on the mapping of ESG risks. The objective is to establish a common base with the double materiality exercise, and to have consistency in the approach to and definition of the issues. The methodology used for its development is consistent with that used for other mapping exercises (see Chapter 2 of this document).

The common foundation is based on the identification of twenty key CSR issues for Publicis Groupe, resulting from a sectoral, documentary and regulatory analysis, supplemented by qualitative interviews with key contacts in the Groupe’s various functions and regions. The mapping process has identified 15 risks, some of which are included in or detail risks from the Groupe's major risk mapping. No risk appeared to be very high and certain.

Nevertheless, five CSR/ESG risks were analyzed in depth:

The results of this work on ESG risk mapping were presented to the Supervisory Board's Audit Committee and ESG Committee in September 2023.