Publicis Groupe completes an assessment of its third parties and performs anti‑corruption‑specific due diligence using a risk‑based approach. Publicis Groupe does 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 4.3.9 of this document).
The Groupe’s anti‑corruption compliance program includes regular monitoring by the Compliance Department and the Internal Audit teams, who conduct audits throughout the year. The Internal Audit, Risk Management and Internal Control Department interacts regularly with the Compliance Department 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 and/or applicable anti‑corruption law by using the email address ethicsconcerns@publicisgroupe.com or the external platform Ethics Concerns, at https://publicis.whispli.com/lp/ ethicsconcerns, rolled out in 2023, the two solutions being part of the same centralized system as described in the Reporting Ethics Concerns Policy (whistleblowing policy). Alerts can be made anonymously and all alerts are treated promptly and confidentially, as described in the Reporting Ethics Concerns policy. All alerts are dealt with by the teams of the Compliance and Internal Audit Departments, reporting to the office of the Secretary General (see Section 4.3.6).
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 Conduct and Ethics Reporting Ethics Concerns Policy or so‑called “whistleblowing” policy. This policy and the system for reporting concerns are accessible to all employees and publicly available in the "CSR Smart data" section of the Groupe’s corporate website.
The recently rolled out external Ethics Concerns platform, available at https:/publicis.whispli.com/lp/ethicsconcerns,/ makes it possible to receive all types of alerts, whether internal or external. The longstanding dedicated email address: ethicsconcerns@publicisgroupe.com is still available for alerts. All whistleblowing alerts received are processed, even those sent anonymously, if they are sufficiently precise and substantiated. 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 resources depending the subject in question, while maintaining strict confidentiality. Whistleblower communications are protected by confidentiality and any form of retaliation against a whistleblower acting in good faith is strictly prohibited.
In 2023, 102 whistleblowing alerts were received and dealt with, of which 89% were internal reports. 74% of the cases concerned HR issues, mainly related to internal operations. The increase in the number of alerts is due to strengthened internal communication and the introduction of the new Ethics Concerns platform. The results of the investigations carried out are communicated to General Management and a report is provided to each Audit Committee.
