Universal Registration Document 2023

4.3.13 Compliance

The Compliance Department reports to the Groupe’s Chief Compliance Officer, who reports to the Secretary General. Its objectives are to promote an ethical culture within the Groupe and to design, deploy and monitor the implementation of compliance programs in all Groupe entities.

This department relies on a network of compliance officers operating at the local level. Under its supervision, they are responsible for coordinating and ensuring the effective deployment of compliance programs within their scope.

Compliance in relation to the GRI (Global Reporting Initiative) guidelines:

• Publicis Groupe, whose core activities involve the provision of intellectual services, has not recorded any incidents involving child labor or forced or compulsory labor, nor incidents relating to the violation of the rights of native populations, nor human rights grievances;
• Publicis Groupe has not experienced any incidents of non‑compliance with voluntary rules and codes to be applied concerning the following: impacts on consumer health and safety; information about its products and services; the provision and use of its services;
• Publicis Groupe has had no complaints filed against it for invasion of privacy or loss of client‑related data, and has not had to declare data breaches to authorities;
• Publicis Groupe has not had to report incidents of non‑compliance with regulations and voluntary codes of application relating to communication, which most often result in opinions or notifications from supervisory or self‑regulatory bodies, each time giving rise to immediate changes;
• Publicis Groupe has not been convicted of conduct contrary to competition law or corruption.

Litigation and Controversies

On February 1, 2024, Publicis Health US indicated in a press release that an agreement had been reached between the Attorneys General of the 50 US states, the District of Columbia and certain territories of the United States regarding the work carried out by the former advertising agency Rosetta on behalf of opioid manufacturers, thus closing three years of discussions. The Attorneys General recognized the good faith and responsible and civic attitude of Publicis Health when signing this agreement. As the former owner of Rosetta, an agency closed for ten years, Publicis Health said:

“This settlement agreement allows us to close three years of discussions, and ends with a net payment of euro 148 million. The total amount of the agreement should directly and quickly help to strengthen the assistance provided to these States to combat the consequences of the opioid crisis.”

The work carried out on behalf of pharmaceutical companies and covered by this regulation has always been fully compliant with the law. It was carried out mainly by Rosetta, a small agency closed for ten years, which was already working with pharmaceutical clients producing opioid‑based treatments when it was acquired thirteen years ago in 2011. Its work on these products has been used only with healthcare providers, never with consumers, using only communication tools and terminologies approved by the FDA (Food and Drug Administration). Rosetta’s role was limited to providing standard services that an advertising agency offers to its clients for products that are still prescribed to patients, covered by the main private insurers, Medicare, and authorized by State pharmaceutical authorities.

“We recognize the broader context in which this law‑compliant work has been conducted. The fight against opioids in the United States requires collaboration between industries, legislators and communities, and we are determined to contribute to it. This is why we have worked to achieve this agreement and reaffirm our long‑standing commitment to reject any future opioid‑related projects.”

The press release is publicly available on the Groupe’s website: www.publicisgroupe.com/fr/news‑fr/communiques‑de‑presse 

In compliance with article R. 225‑105 of the French Commercial Code and supplementary information required by other French legal texts, the environmental impacts are dealt with in Section 4.1. Some indicators do not apply to Publicis Groupe, given its service‑based and intellectual activities, namely:

• The resources dedicated to preventing environmental risks and pollution. Given the insignificant level of these types of risks, the Groupe does not envisage writing any provisions and guarantees for environmental risks or risks associated with climate change;
• The consideration of noise pollution and other forms of activity‑specific pollution;
• Measures taken to prevent, reduce or repair air, water and soil pollution (including land use) affecting the environment.

Concerning article R. 225‑102-&, III of the French Commercial Code, “promoting the nation‑army bond and supporting commitment to the reserves" is a subject that has not yet been addressed.