The Anti-Corruption Policy is accessible to all employees within the Anti-Bribery & Anti-Corruption chapter in Janus. In France, the anti-corruption policy is incorporated into the internal rules and, for this reason, has been the subject of the employee representative consultation procedure provided for in article L. 1321-4 of the French Labor Code. It can be accessed by the general public in the “CSR Smart data” section of the Groupe’s website.
[G1-1-10 (a), G1-3-20]
The corruption risk mapping exercise was updated in 2024 by the Internal Audit, Internal Control and Risk Management Department, in collaboration with the Compliance Department. The approach covers all of the Groupe’s activities and regions. The results were shared with the Secretary General and the Groupe Chief Financial Officer, and were presented to the Audit and Financial Risks Committee.
The Compliance Department relies on the mapping exercise to update the compliance program, policies, procedures, training and controls.
Publicis Groupe has made an online anti-bribery & anti-corruption training program available to all employees. This training program includes a training course, is 25 minutes long and is designed to guide employees in preventing and detecting corruption risks by applying the Zero Tolerance principle. This training also covers how the whistleblowing system works. Specifically, the course highlights the rules around giving and receiving gifts and entertainment, working with public officials, and engaging third party representatives. The full course is mandatory for all employees, who are asked to complete it when they join the Groupe. The Groupe also provided an online training course on the Groupe’s Whistleblowing Policy, and how to raise a good faith concern about unethical behavior in the workplace. It reminded employees of the importance of raising their voice when they witness unethical behavior, how to report good faith concerns, including anonymously, if preferred, and how the Groupe treats concerns (promptly, confidentially, and without retaliation). Annual online training on anti-corruption and reporting ethics issues (“Reporting Ethics concerns”), the content of which may be updated to reflect updates to the anti-corruption program or the results of the corruption risk mapping, is made available to all employees, including those in positions of risk. [G1-1-10 (g), G1-3-21 (a)] In-person training is also available for employees at increased risk of exposure to corruption. Legal and compliance teams at Groupe and country/regional levels host training sessions during the year to targeted employee audiences and aim to raise awareness and strengthen compliance with the Groupe’s rules around preventing and detecting corruption. [G1-1-10 (h)]
The Groupe Compliance Department regularly monitors attendance rates to both the online and in-person training programs and ensures the materials are effective at communicating the Groupe’s commitment to ethics. The corruption risk mapping was finalized at the end of 2024; it is on this basis that the so-called risk categories are updated. Specific training actions will be undertaken in 2025. [G1-1-10 (h), G1-3-21 (b)]
Publicis Groupe completes an assessment of its third parties and performs anti-corruption-specific due diligence using a risk-based approach. Publicis Groupe does not work with any third party that presents a risk of corruption or that does not agree to comply with anti-corruption laws and the Groupe’s anti-corruption policy. In this regard, suppliers are assessed and verified before the contract is signed. For more details on the Groupe’s third-party assessment policy in calls for tender (see Section 4.3.10.2).
The Groupe’s anti-corruption compliance program includes regular monitoring by the Compliance Department and Internal Audit teams, who conduct audits in the agencies throughout the year. The Internal Audit, Risk Management and Internal Control Department interacts regularly with the Compliance Department in order to optimize audit and internal control practices and contribute to the anti-corruption program.
Accounting controls dedicated to the prevention of corruption are also periodically implemented by the Financial Monitoring Controls (FMC). Audits are carried out by Internal Audit or external auditors as part of the certification audits of the financial statements provided for in article L. 823-9 of the French Commercial Code.
