Policy Note [ESRS 2 MDR-P-63, 64 & 65]: the policies that structure Company life are developed at several levels:
- Groupe: Janus, the Code of Ethics and Conduct, is the reference for all other policies (see Section 3.1.1.6). It is based on the Groupe’s core values and is backed by major international standards such as the United Nations Global Compact. It brings together all the standards with which all employees must comply, without exception. It is made available to all employees on the Marcel platform and the Groupe’s internal website. In addition, it is the subject of mandatory training, generally held annually.
Janus is subject to an annual review. Some policies may be adjusted during the year, particularly in the event of regulatory change. Information is then sent to employees(e.g., anti-corruption policy);
- countries: the policies establish the local implementation measures in compliance with local regulations and their specific characteristics. They are reviewed annually and adjusted regularly according to new or improved systems, particularly in the social field;
- agency/entity or network: for historical reasons, some entities may maintain additional policies, as they are directly related to the activity and its operational characteristics. They are revised as needed.
4.1.9 Double materiality analysis – impact and financial
The double materiality analysis is based on the premise of examining, on the one hand, financial materiality, with the impact of the deterioration of societal and environmental conditions on the Company’s activity and its financial impacts, and, on the other hand, the materiality of impact, with the measurement of the impact of the Company’s activities under these same conditions.
The work was carried out at Groupe level in 2023 with the assistance of Salterbaxter(1) and involvement of the Risk Management team (see ESG risk mapping, Section 4.1.5), based on the same key CSR issues for Publicis Groupe as those that formed the basis of the ESG risk mapping. The work on ESG risks was also reconciled with the work carried out in 2024 on the risks related to the Duty of Care Plan (Section 4.6). Three groups of stakeholders were asked to take part in qualitative interviews: employees (at various levels, managers and employees), clients (mainly international clients) and investors. The views expressed by consumers and users have been included on the basis of the results of surveys carried out by third parties or the Groupe’s agencies (see Section 4.3.12.6). The points of view of associations and NGOs were taken into account with regard to direct local discussions and/or their own publications (see Section 4.1.8). As for universities and schools, close local relationships within the framework of our recruitment programs make it possible to collect their views (see Section 4.1.8).
The scope taken into account is that of the Company’s own operations, as well as its business relationships with its clients downstream or suppliers upstream; therefore mainly the Tier 1 value chain, but sometimes beyond.
[ESRS 2 SBM-3-48 (b) to (g), ESRS 2 IRO-1-53 (b) i, ii, iii]
The five work steps were as follows:
- contextual and sectoral, documentary and regulatory analysis. The literature review took into account regulatory aspects and the interpretation of texts, the point of view of professional organizations and a review of the criticisms leveled at the communications industry by associations and activists;
- cross-checking of work with that of ESG risk mapping;
- qualitative interviews with clients from different sectors in several countries including the United States, the United Kingdom and France;
- qualitative interviews with some ESG investors;
- qualitative internal interviews with employees, supplemented by webinars in four countries in 2023 (the United States, France, India and the United Kingdom), and repeated in 2024 in France and the United Kingdom to deepen the opportunity component. These interviews were supplemented by an internal survey at the beginning of 2024 to which 350 employees familiar with CSR responded, using the internal Marcel Intelligence platform. A second survey was carried out in the same way at the end of 2024, confirming the findings from the beginning of the year. Publicis Groupe does not have a Social and Environmental Committee (CSE) at Groupe level, as the Groupe Works Council in France does not have the assignments of a CSE.[ESRS 2 IRO-1-53 (a) & (b) i to iv ; ESRS 2 IRO-1-53 (e) to (h)]
The double materiality analysis prioritized IRO (Impacts, Risks and Opportunities) based on:
- the four-level severity of impacts scale (1-low, 2-moderate, 3-high, 4-major) used to prioritize the Groupe’s risks (see Section 2.2.4);
- the four-level probability of occurrence scale (1-rare, 2-possible, 3-probable, 4-certain) used to prioritize the Groupe’s risks (see Section 2,2,4);
- the time frame used is that recommended by the ESRS and is presented in the table below based on the concepts of short term (one year), medium term (between one and five years) or long term (more than five years).
