Universal Registration Document 2024

Glossary

4.4.1.4 Opportunities related to ethics and business conduct issues

Opportunities are essentially based on two aspects: on the one hand, client satisfaction with regard to the behavior of the entities and employees who work alongside them; and on the other hand, the satisfaction of employees who appreciate their working environment and the shared culture. It is therefore a factor that attracts both clients and employees, and it also contributes to customer and employee loyalty. Publicis Groupe has always been very firm on ethical issues, which are deeply rooted in the Company’s values, and accessible to employees and stakeholders alike through the Janus Code of Conduct and Ethics.

4.4.2 Janus: policies and ethical principles in business conduct

Janus is the Groupe’s Code of Conduct and Ethics and applies to all managers and their teams. It consists of a code of conduct and detailed operating rules. The Code of Conduct and Ethics applies to all employees without exception. In 2024, 90% of the Groupe’s employees received training in the Janus Code and its contents. Training on the Janus Code of Conduct and Ethics takes various forms: online training in Marcel, awareness-raising sessions during programs for new employees, and more specific internal sessions for the most exposed positions. In the induction programs, Janus is explained as part of the presentation of the Groupe and its activities. The key principles are detailed in particular regarding the standards of behavior of managers and teams, and the rules of operation to comply with fair practices. These include the “Zero Tolerance” principle in terms of discrimination, harassment, and violence at work; rules regarding conflicts of interest, fraud, and the prevention and combating of corruption; data protection; the key points of the HR policy; and a reminder of the major principles adhered to by the Groupe, such as the United Nations Global Compact.[G1-1-7, G1-1-8, G1-1-9] 

In terms of business, one of the Groupe’s historic principles is its refusal to take part in partisan communications campaigns of any kind. The Groupe refuses to work for political parties, cults or ideological propaganda organizations, and refuses any request for funding, contribution or free support.

Several extracts from Janus are available on the CSR section of the Groupe’s website, at the following address: www.publicisgroupe-csr-smart-data.com/fr/links.

Janus

Indicators 2023 2024
% Employees trained in internal Janus Code of Conduct and Ethics

% Employees trained in internal Janus Code of Conduct and Ethics

2023

79%*

% Employees trained in internal Janus Code of Conduct and Ethics

2024

90%*
Of which % ABAC (Anti-Bribery & Anti-Corruption)

Of which % ABAC (Anti-Bribery & Anti-Corruption)

2023

80%

Of which % ABAC (Anti-Bribery & Anti-Corruption)

2024

90%

Of which % GDPR (Data Protection)

Of which % GDPR (Data Protection)

2023

84%

Of which % GDPR (Data Protection)

2024

89%

Of which % GSO (Data Security)

Of which % GSO (Data Security)

2023

84%

Of which % GSO (Data Security)

2024

89%

4.4.2.1 Centralized whistleblowing system

Employees, suppliers and all other parties may report any concern related to a potential violation of laws or company policies on fraud, corruption, harassment, discrimination or any other ethics concerns, as stated in the Janus Code of Conduct and Ethics and the Reporting Concerns, or “whistleblowing” policy. This policy and the system for reporting concerns are accessible to all employees and publicly available in the “CSR Smart data” section of the Groupe’s corporate website.[G1-1-10 (c) & (e)]

Each year, all Groupe employees receive a message from the Secretary General informing them of the existence of the whistleblowing system, accompanied by a video reminding them of its operation and with examples of behavior contrary to the Company’s rules. Locally in the countries, the HR/Talent teams also disseminate a similar message, with contextual information allowing employees to understand why and how to use it. The external Ethics Concerns platform, available at https://publicis.whispli.com/lp/ ethicsconcerns, makes it possible to receive all types of reports, whether internal or external.[G1-1-10 (e)] All whistleblowing reports received are processed, even those sent anonymously, if they are sufficiently precise and substantiated. They are dealt with by the Compliance Department, with support from the Internal Audit Department, the Legal Department or the Human Resources Department under the supervision of the Secretary General. Investigations are carried out by the Internal Audit Department or by a lawyer, using the appropriate resources depending the subject in question, while maintaining strict confidentiality. Whistleblower communications are protected by confidentiality, and any form of retaliation against a whistleblower acting in good faith is strictly prohibited.[G1-1-10 (c)]