4.3.9 Responsible purchasing
4.3.9.1 Review process and Due Diligence
In 2023, and for the last four 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:
- risk analysis: this part covers a wide range of subjects, such as the financial health of the company or supplier reputation issues. In 2023, the Groupe Procurement Department activated and deployed the Supplier Risk module of the Ariba SLP platform, which covers legal compliance, financial situation, CSR assessment and operational issues;
- anti‑corruption: teams carry out a risk analysis to assess suppliers. Publicis Groupe will not work with suppliers that may present a risk of corruption or that are not in compliance with anti‑corruption laws and the Groupe’s anti‑corruption policy;
- 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). The GDPO (Global Data Privacy Office) performs critical reviews according to the level of data protection risks identified. The GDPO has the processes to assess data protection risks and proposes appropriate mitigation measures;
- information systems security: the GSO (Groupe Security Office) teams carry out regular assessments of supplier security systems. This review includes tests (due diligence) to verify the security of the supplier’s systems in order to verify their compliance and security and their alignment with the Groupe’s policies. The GSO informs of any risks and validates the service continuity plans proposed by suppliers;
- 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 (see Section 4.3.9.3), 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.
The Groupe CSR Department participates in Supplier seminars organized by the Groupe Purchasing Department, with a particular focus in 2023 on regulatory changes related to the CSRD and the Groupe’s expectations of its partners. 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 Conduct and Ethics and act in a professional and rigorous manner, free from any conflicts of interest.
In 2023, the Groupe Procurement Department launched a new engagement and individual review program with 111 major suppliers considered strategic by the Groupe on five mandatory topics:
- application of and compliance with the CSR for Business Guidelines;
- accessibility/e‑accessibility;
- Net Zero climate commitments for 2050 (at the latest);
- CSR assessment by a third party such as EcoVadis (minimum score of 45);
- commitment to the WorkingWithCancer initiative.
This program is intended to ensure supplier compliance, with a view to continuous improvement. 71% of these 111 strategic suppliers were in full compliance in 2023 on the five criteria, with the objective being to reach 100% for the top 200 strategic suppliers by 2025. This 71% is not comparable with the rate of 98% indicated in 2022 because the program was not the same: fewer suppliers and three out of the five subjects covered by the new program.
Purchasers are regularly trained on CSR issues by the CSR Manager of the Procurement Department, who works closely with the Groupe CSR Department, and they took part in conferences/webinar with suppliers on these subjects. Regulatory changes, such as changes to the CSR for Business Guidelines, are reviewed with the teams at least once a year.
