Universal Registration Document 2023

The anti‑corruption compliance program includes:

1. an Anti‑Bribery & Anti‑Corruption Policy, including a helpful guideline to illustrate how Publicis employees should behave;
2. a system for reporting concerns (also known as a whistleblowing system), which can be used to raise concerns about violations of Publicis policy, as described in the Reporting Ethics Concerns Policy;
3. regular corruption risk mapping, which analyzes the risks of corruption;
4. third party (clients, suppliers and partners) due diligence processes;
5. accounting procedures and controls to prevent and detect corruption;
6. employee training, both online and in‑person;
7. monitoring of the effectiveness and implementation of the Groupe’s anti‑corruption compliance program;
8. sanctions for violations of the anti‑corruption policy.

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.

Anti‑Bribery & Anti‑Corruption Policy

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:

• a strict prohibition of any form of bribery, corruption or influence peddling;
• potential significant risk areas requiring a high degree of vigilance;
• rules relating to gifts and entertainment, engaging with third parties, lobbying and more;
• a reminder on the system for reporting any violation of this policy, Janus, or applicable anti‑corruption laws;
• helpful guidance for employees to illustrate how Publicis employees should behave and what risks to avoid;
• the policy was last updated at the beginning of 2024 in order to include additional practical guidance (DOs/DON’Ts) and to improve upon the 2023 version of the policy which was revised following the 2022 corruption risk mapping exercise. Updates to the policy have reinforced the fact that it applies to business partners, that special attention must be paid to working with government partners and that conflicts of interest must be avoided.

The Anti‑Corruption Policy is accessible to all employees within 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.

Employee Training and Monitoring

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 employees in preventing and detecting corruption risks 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. 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 within one year of joining the Groupe. 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. The Groupe also provided an online training course on the Groupe’s Whistleblowing 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.

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 2023, 80% of employees had received training (workforce at December 31, 2023).