Universal Registration Document 2024

4.1 GENERAL INFORMATION

4.1.1 General basis for preparation

Notice to readers on the application of the CSRD and ESRS for Publicis Groupe

The European directive, the CSRD (Corporate Sustainability Reporting Directive) and ESRS (European Sustainability Reporting Standards), are primarily intended to bring non-financial reporting to the same level of requirements as financial reporting, to give a more complete understanding of the Company’s activities and its impacts. This Directive also aims to harmonize and to improve the quality of sustainability information published by European companies. The regulator has given companies the opportunity to report on their progress in implementing the texts, so certain data points will be available gradually (in 2025 or 2026). This new law, transposed in France, requires companies to adopt a more complex approach than for the preparation of the NFRD, and it is more granular in many areas.

The Groupe has endeavored to apply the standards-related requirements set by the ESRS, as applicable on the date of the sustainability statement, based on available data and information. The use of scope limitations is mentioned on a case-by-case basis for certain data, as specified in the contextual elements, or at the end of each topical ESRS. Finally, certain information required by the ESRS standards was not available at year-end (December 31, 2024) due to the new time constraints required to report this new information.

2024 is the first year of application; the Groupe will improve this sustainability reporting with regard to additional market recommendations, positions or interpretations as soon as they become available. All of this information will be provided in 2025.

Sustainability reporting covers all Publicis Groupe subsidiaries worldwide, aligned with the consolidated scope of financial reporting from January 1 to December 31, 2024. [ESRS 2 BP-1-5 (b) i] Any exclusions are indicated in the scope for the metrics concerned (see Section 4.1.2). Companies acquired less than six months before December 31, 2024 are included in all social metrics, but not in environmental metrics. As these are new challenges for these companies joining the Groupe, we are giving them some time to familiarize themselves with the reporting requirements.

This sustainability report is based on a CSR reporting process that has been strengthened following preparatory work undertaken since 2022 in anticipation of the European CSRD Directive coming into force.

Work in advance of the reporting: eight topical working groups were set up in 2023 on the basis of the CSR Steering Committee, in place since 2009, to work on implementing regulatory changes, with each department taking ownership of their respective CSRD and ESRS. Joint work between subgroups was carried out on shared topics such as the double materiality analysis. A regular progress report was presented to the Groupe’s Secretary General and Chief Impact Officer. The initial phase was to analyze the discrepancies between the information available in the non-financial reporting in its former form (NFRD format) and the information expected by the new regulations based on the 1,000 data points of the ESRS, reviewed one by one. The double materiality analysis explored the 20 key issues in greater depth and defined their scope in terms of impacts, risks and opportunities (IRO). This analysis continued in 2024, identifying the four ESRS standards considered non-material:

• ESRS E2 - Pollution: with regard to the double materiality analysis and the type of intellectual services offered to the Groupe’s clients, pollution issues do not appear to be applicable. This does not exempt the Company from measuring its waste and type of waste or improving its waste sorting. Since 2009, the Company has been measuring the volume of its waste and e-waste every year in order to reduce it and promote efficient recycling. The Groupe questions its suppliers on this matter as part of their CSR assessments. In addition, the Groupe annually monitors the commitments of its major clients in terms of the environment, in particular their climate trajectory and the reduction of their impacts. [ESRS 2 IRO- 2-58]
• ESRS E3 - Water and marine resources: the double materiality analysis does not identify this topic as material, which is consistent with the Company’s intellectual services activities. However, the quantities of water consumed in offices around the world have been traced since 2009, and the objective remains to limit the use of this resource. The Groupe also asks its suppliers about their impacts on their management of water resources, in particular consumer activities such as data centers and the cloud. [ESRS 2 IRO-2-58]
• ESRS E4 - Biodiversity and ecosystems: given that it provides intellectual services activities to companies, the Groupe’s double materiality analysis does not identify this as a major topic. However, aware that these are natural dimensions that need to be better understood, the Groupe carried out an initial biodiversity footprint analysis in 2023. This work did not reveal any significant impacts. [ESRS 2 IRO-2-58]
• ESRS S3 - Affected communities: the Groupe has historically been very committed to local communities in the countries and cities where the teams work. However, the double materiality analysis did not identify this topic as material. The Groupe will continue to analyze the actions it carries out in favor of communities, in particular its societal commitments and actions promoting public interest causes. [ESRS 2 IRO-2-58]