Universal Registration Document 2023

4. Corporate Social Responsibility Non-Financial Performance - AFR

4.3.10.2  Risk identification and methodology

The purpose of the duty of vigilance risk mapping is to identify and prioritize the risks and serious violations related to the activity of the Company, its subsidiaries and its suppliers with regard to human rights and fundamental freedoms, personal health and safety and environmental matters. It is prepared by the Internal Audit and Risk Department according to the common risk mapping methodology introduced by the Groupe as described in Chapter 2, Section 2.2.4.

A first mapping was carried out in 2017. It has been regularly updated since then. The completion of the ESG risk mapping in 2023 covered certain aspects of the Duty of Care. It confirmed the absence of serious risk in this area. The mapping of risks related to the Duty of Care will be updated again in light of the future European directive (Corporate Sustainability Due Diligence Directive).

As the core of the Company’s activity is business services, the mapping mainly refers to risks relating to human rights and fundamental freedoms, on the one hand, and risks related to personal health and safety, on the other hand; risks related to the environment are low in terms of both probability and potential impact.

The risk mapping carried out as part of the Duty of Care did not detect any risk or serious violation of human rights and fundamental freedoms, personal health and safety, or the environment.

However, even in the absence of risks or serious harm, certain risks described below require special attention and are closely monitored by the Groupe.  

4.3.10.2.1 Risks monitored regarding human rights and fundamental freedoms

Human rights and fundamental freedoms must be protected and respected whether in relation to employees, clients and partners, or suppliers:

  • on the effective abolition of child labor: Publicis Groupe only hires adult employees. Short‑term job shadowing (lasting a maximum of one to three weeks) may, however, be offered to minors as part of their school career or professional apprenticeship, subject to obtaining authorization from parents and in agreement with the educational institution;
  • on the elimination of all forms of forced labor or modern slavery and the fight against discrimination: the Groupe applies a Zero Tolerance policy with regard to forced labor or modern slavery, and discrimination in all its forms, against all persons. The Groupe’s employees may receive legal support in the performance of their duties in countries with low levels of legal protection;
  • on freedom of expression and freedom of association: freedom of movement, association and expression are some of the key principles recognized and protected by the Groupe;
  • on combating physical, sexual or moral harassment: the Groupe has a Zero Tolerance policy with regard to all forms of harassment and regularly trains its employees on these topics;
  • on women’s rights: in 2018, Publicis Groupe signed the Women Empowerment Principles (WEP), seven fundamental principles listed by the United Nations to act tangibly to promote women’s rights (or equality of rights) worldwide and at all levels. Publicis Groupe is the owner of the Women’s Forum, an international platform that defends women’s rights and human rights, as well as the essential contribution of women to the economy and society;
  • on the protection of personal data: as these data are specific to each individual, they must be protected over time and be protected from any risk of theft, intrusion or falsification in accordance with the regulations in force. The guidelines of the Global Data Protection Office (GDPO) in terms of data protection were applied by the operational teams, and the Global Security Office (GSO) has strengthened its controls at all levels, also monitored by the Internal Audit Department. (See Sections 4.3.3 and 4.3.4 for more information).

On these six points, the Groupe asks its suppliers to comply with these standards, which are part of the CSR for Business Guidelines and are appended to the contracts signed between the Groupe and its suppliers.

Pro bono campaigns, like volunteering (see Section 4.2.9) in support of organizations or general interest causes promoting human rights (of women, men and children) and opposing all forms of exclusion and discrimination, demonstrate the long‑term commitment of the Groupe, as well as its agencies and employees, to defending human rights.