Universal Registration Document 2023

2. Risk and Risk management - AFR

To carry out their assignments, the internal audit teams use a specific IT tool. The internal auditors' work programs are aligned with the Groupe's main ERP systems and use specific extracts and reports, in addition to the contribution of a dedicated tool for data analytics.

Internal audit assignments are systematically reported, among others, to the Chairman of the Groupe’s Management Board. A summary of all reports issued is presented at each Audit Committee meeting.

The action plans proposed by the auditees based on the audit recommendations are monitored systematically by the central internal audit team using an IT application. Additionally, specific on‑site follow‑up assignments are launched for the most critical reports or when action plan indicators clearly contradict the commitments made by the audited entities. A report on the implementation status of audit recommendations is regularly presented to country/ regional management as well as to the Audit Committee.

Internal (particularly in terms of HR investigations) or external assistance is requested when needed to support the Internal Audit Department, when special skills or techniques are necessary to conduct internal investigations.

The Internal Audit Department of Publicis Groupe works in accordance with the international professional standards issued by the IIA (The lnstitute of Internal Auditors) and first obtained the certification of its activities from the IFACI (French Institute for Audit and Internal Control) in March 2017. This certification confirms the ability of the Publicis Groupe Internal Audit Department to fully carry out its duties. It was renewed in March 2020, then in March 2023 and confirmed in March 2024 after annual follow‑up audits.

2.2.3.2 Internal financial control framework

Publicis Groupe has set up:  

  • key corporate controls over financial reporting (consolidation, treasury, tax, legal, etc.), which are reviewed annually by the Internal Audit Department;
  • a program called Financial Monitoring Controls (FMC), implemented in all Groupe entities and based on a list of key controls for the main processes contributing to financial and non‑financial reporting. Their implementation is monitored at two levels
    • a quarterly self‑assessment, submitted by all Groupe entities via a common tool, which contributes to accountability and transparency regarding the effectiveness of controls,
    • teams dedicated to FMC reviews are established at regional level. These teams are functionally linked to the Finance Department of each region and hierarchically to the Groupe’s Internal Audit, Risk Management and Internal Control Department, which oversees them, coordinates their work, and compiles their results. These teams follow a systematic review plan covering about 60% of the Groupe’s consolidated revenue in 2023.
2.2.3.3 Monitoring by the Legal and Compliance departments

The Groupe’s Legal Department regularly monitors litigation‑related risks within the Groupe. A summary of any significant legal disputes, as well as an estimate of their potential impacts, are presented to the Groupe’s senior management four time a year. The main legal disputes and current or finalized investigations, where relevant, are also discussed at each Audit Committee meeting.

The Compliance Department is managed by 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 is supported by a network of compliance members operating at the local level. Under its supervision, they are responsible for coordinating and ensuring the effective deployment of compliance programs within their scope (see Section 4.3.5 of this document).

2.2.4 Risk management framework

In coordination with senior management, the business management teams of the countries/regions/business lines as well as the shared service centers are heavily involved in monitoring risks facing the Groupe. They continually analyze the Groupe’s exposure to the loss of significant contracts, to risks of conflicts of interest and to changes in contractual clauses.

The risks relating to accounting information, external growth strategy, management of the liquidity position, foreign currencies and changes in the Groupe’s debt or tax position are monitored by the Finance Department, in cooperation with the senior management.

The risks associated with accounting and financial information are also monitored via the FMC program, managed by the Internal Audit, Risk Management and Internal Control Department.