Universal Registration Document 2024

Glossary

In 2024, 221 whistleblowing reports were received and dealt with, of which 94% were internal reports. 70% of the cases concerned HR topics, mainly related to internal operations. The increase in the number of alerts is due to strengthened internal communication and the introduction of the new Ethics Concerns platform – https://publicis.whispli.com/lp/ ethicsconcerns. The results of the investigations carried out are communicated to Executive Management and a report is provided to each Audit and Financial Risks Committee.

Indicators 2022 2023 2024
Total number of alerts received

Total number of alerts received

2022

84

Total number of alerts received

2023

102

Total number of alerts received

2024

221
Of which % internal reports [S1-17]

Of which % internal reports

[S1-17]

2022

70%

Of which % internal reports

[S1-17]

2023

89%

Of which % internal reports

[S1-17]

2024

94%
Of which % external alerts
  • of which number of reports from a supplier: 1 [S2-3] 
  • of which number of reports from a community: 0 [S3-3]
  • of which number of reports from a consumer: 1 [S4-3]

Of which % external alerts

  • of which number of reports from a supplier: 1 [S2-3] 
  • of which number of reports from a community: 0 [S3-3]
  • of which number of reports from a consumer: 1 [S4-3]

2022

23%

Of which % external alerts

  • of which number of reports from a supplier: 1 [S2-3] 
  • of which number of reports from a community: 0 [S3-3]
  • of which number of reports from a consumer: 1 [S4-3]

2023

11%

Of which % external alerts

  • of which number of reports from a supplier: 1 [S2-3] 
  • of which number of reports from a community: 0 [S3-3]
  • of which number of reports from a consumer: 1 [S4-3]

2024

5%
Of which % anonymous reports

Of which % anonymous reports

2022

7%

Of which % anonymous reports

2023

29%

Of which % anonymous reports

2024

31%
HR topics (%)

HR topics (%)

2022

52%

HR topics (%)

2023

74%

HR topics (%)

2024

70%
Topics related to fraud, corruption, conflicts of interest (%)

Topics related to fraud, corruption, conflicts of interest (%)

2022

23%

Topics related to fraud, corruption, conflicts of interest (%)

2023

15%

Topics related to fraud, corruption, conflicts of interest (%)

2024

27%
Requests via the dedicated external Ethics Concerns line (%)

Requests

via

the dedicated external Ethics Concerns line (%)

2022

70%

Requests

via

the dedicated external Ethics Concerns line (%)

2023

84%

Requests

via

the dedicated external Ethics Concerns line (%)

2024

77%

4.4.3 Anti-Corruption Program

The Groupe complies with the provisions of the French law known as “Sapin II.” It has implemented a compliance program as provided for by law, including the Janus Code of Conduct and Ethics and the anti-bribery and anti-corruption policy, illustrating acts and behaviors relating to corruption or influence peddling that are prohibited. The Groupe is also in compliance with the other anti-corruption laws applicable where it operates.

The anti-corruption compliance program includes:

  1. an Anti-Bribery & Anti-Corruption Policy, including a helpful guide to illustrate how Publicis Groupe employees should behave;
  2. a system for reporting concerns (also known as a whistleblowing system), which can be used to raise concerns about violations of Publicis policy, as described in the Whistleblowing policy;
  3. regular risk mapping, which analyzes the risks of corruption;
  4. third party (clients, suppliers and partners) due diligence processes;
  5. accounting procedures and controls to prevent and detect corruption;
  6. employee training, both online and in person;
  7. monitoring of the effectiveness and implementation of the Groupe’s anti-corruption compliance program;
  8. sanctions for violations of the anti-corruption policy.

The Groupe’s Legal and Compliance experts play an important role in terms of awareness and the application of anti-corruption laws and regulations. They are part of the Shared Service Centers (Re:Sources) and report to the Groupe’s Compliance Office and Groupe Legal Department, which constantly monitors the program. Their mission is to prevent bribery and corruption and to help ensure compliance processes and procedures are in place, applied and adapted to local markets. The aim is to maintain the high standards that comply with current applicable regulations and the Groupe ethics rules and policies. The legal and compliance experts who support the implementation and monitoring of the anti-corruption compliance program report to the Groupe’s Chief Compliance Officer (CCO). Reporting to the Groupe Secretary General, a member of the Management Committee, the CCO oversees the Groupe’s compliance programs, including the anti-corruption compliance program.

[G1-3-18-(a) & (b)]

4.4.3.1 Anti-Bribery & Anti-Corruption Policy

The Anti-Bribery & Anti-Corruption Policy is rolled out at all levels of the organization and is based on the principle of zero tolerance for any form of bribery or corruption. All employees must comply with this Policy, as well as with all applicable anti-corruption laws. This Policy includes:

  • a strict prohibition on any form of bribery, corruption or influence peddling;
  • potential significant risk areas requiring a high degree of vigilance;
  • rules relating to gifts and entertainment, engaging with third parties, lobbying and more;
  • a reminder on the system for reporting any violation of this policy or applicable anti-corruption laws;
  • helpful guidance for Publicis employees on how to behave and what risks to avoid;
  • the policy was last updated at the beginning of 2024 in order to include additional practical guidance (DOs/ DON’Ts) and to improve upon the 2023 version of the policy, which was revised following the 2022 corruption risk mapping exercise. Updates to the policy have reinforced the fact that it applies to business partners, that special attention must be paid to working with government partners and that conflicts of interest must be avoided.