Universal Registration Document 2024

Internal Audit reports on its work, including on fraud and corruption prevention, to Executive Management, and regular reports are presented to the Audit and Financial Risks Committee. The Internal Audit Department also shares its work with the Compliance Department to influence decisions aimed at updating the policies, processes and procedures of the anti-corruption compliance program.

[G1-3-18 (c)] 

4.4.3.6 Whistleblowing

Employees, clients, suppliers and third parties can report violations of the Anti-Bribery & Anti-Corruption Policy and/ or applicable anti-corruption laws using the external Ethics Concerns platform, rolled out in 2023 and available at https://publicis.whispli.com/lp/ethicsconcerns. Alerts can be made anonymously and all alerts are treated promptly and confidentially, as described in the Reporting Ethics Concerns policy. All whistleblowing reports are reviewed by the Compliance Department or the Internal Audit Department, under the responsibility of the Secretary General (see Section 4.4.2.1).

[G1-1-10 (c) & (e), G1-1-18 (b) & (c)] 

/ Table on anti-corruption policy violations [G1-4-24 (a), G1-5-25 (a) to (d)]

4.4.3.7 Sanctions

Any employee who violates the Anti-Bribery & Anti-Corruption policy may be subject to disciplinary action, the result of which may be severe penalties up to and including dismissal. Immediate measures may be taken should suppliers contravene this Policy. 

4.4.3.8 Lobbying practices

Some assignments may involve lobbying and strategies to influence decision-makers. The lobbying teams operate in compliance with the laws and the Groupe’s rules, particularly concerning combating conflicts of interest and anti-corruption. In accordance with legal obligations and best practices, the teams concerned are identified in the digital repertoire of representatives of interests managed by the High Authority for the Transparency of Public Life in France (HATVP). 

Publicis Groupe did not lobby on its own behalf in 2024.

Publicis has the historical principle of refusing to work for partisan campaigns (political parties, cults or ideological organizations). The Company does not financially or otherwise support such organizations. This clear and public position is included in Janus, the Groupe’s Code of Conduct and Ethics, and applies everywhere.

[G1-5-28 (a) & (b), G1-5-29]

4.4.3.9 Commitment to professional organizations

The Groupe is active in professional organizations in all countries and its commitment is always publicly identifiable on the websites of these organizations.

Publicis Groupe is a member of professional organizations in communications and digital activities in the major countries where the Groupe operates. In order to ensure strategic alignment with the positions taken in these forums, the Groupe and its subsidiaries are represented by one of the local managers. At the international level and on a few selected and limited projects, corporate teams are involved in certain work, such as:

• for more than 80 years, the communications sector has been governed internationally by the Marketing Code of the ICC (International Chamber of Commerce –www.iccwbo.org). This code is the benchmark in self-regulation and best practices for advertising and marketing: Advertising and Marketing CommunicationPractice – ICC Code. The founding principles are that all communication must be legal, decent, honest, truth ful and socially responsible. This code is neutral in terms oftechnology and media; no player can derogate from it. It obviously includes digital communications and mobile applications, and the Internet of Things. This code also incorporates issues related to data collection and protection and the right to privacy, and takes into account the different needs of different types of audiences, including vulnerable people. Advertising claims related to climate change and environmental issues have been clarified, in order to clarify the proliferation of arguments and allow consumers to better navigate. The ICC Framework for Responsible Environmental Marketing Communication reports on this collective work on recommended standards. The objective of this guide designed for industry-professionals is to ban all forms of greenwashing. It includes an Environmental Checklist intended to facilitate the teams’ work and to have clear arguments;
• Ad Net Zero: Publicis Groupe is one of the founding entities of the sector initiative led by the British agency inter-professional body. After making the calculator AdGreen available, the interprofessional organization and the Communications company groups have decided to work together on a set of methodologies for calculating the carbon footprint and environmental footprint of the business lines, products and services. The challenge is to define a common framework ensuring that everyone uses the same measurement methods. Ad Net Zero worked with the Cannes Lions (the profession’s major annual event in Cannes in June) to ensure that CSR criteria were included in all applications submitted to the organizers and the various juries. Since 2022, Ad Net Zero has been set up in the United States with the aim of defining a common methodology for the impact of broadcasting and the media. The initiative was extended in 2023 to Australia/New Zealand and all of Europe in order to align practices behind a single standard. University work with the University of Oxford and Saïd Business School was undertaken to find a method to better assess the indirect environmental impacts of the media, with the publication of the GMSF (Global Media Sustainability Framework). This reference framework enables the carbon footprint to be measured from advertising. Aligned with the GHG Protocol, this framework will be integrated into A.L.I.C.E., the Groupe’s carbon calculator, in 2025;
• Groupe agencies play an active role in national and international ad hoc professional organizations. Worthy of note is the work carried out with the IAB (Interactive Advertising Bureau) and the MRC (Media Rating Council) on the visibility of digital advertising, and how this can be quantified (viewability). Publicis Media was the first agency to be Gold Standard certified in the past few years. This work is done in close cooperation with other professional organizations such as the 4As (American Association for Advertising Agencies), particularly the 4As Privacy Committee, and the ASRC (Advertising Self- Regulatory Council) in the United States, as well as the EASA (European Advertising Standards Alliance);
•  the Trustworthy Accountability Group (TAG) is the first cross-industry initiative of its kind dedicated to the fight against criminality in the digital advertising supply chain. Its work focuses on four areas: eradicating illicit traffic, combating malware, fighting against online piracy and promoting transparency (TAG Anti-Piracy Pledge). The goal is to ensure brand safety; that is to say, to ensure brands do not appear on inappropriate sites or environments. The TAG Registry was the second part of the “Verified by TAG” program, whose twofold aim is to combat fraud and crime related to the online advertising sector, and to promote best practices. Publicis Groupe is one of the companies integrated in the TAG Registry. Publicis Media was the first group to be awarded “TAG Platinum” status in 2019, and it has since maintained its compliance in the following areas: TAG Certified Against Fraud, TAG Certified Against Piracy, and TAG Certified Against Malware. It is fully compliant with the TAG Brand Safety Guidelines;
• Digital Ad Trust: this French initiative, launched in 2017, has been fully operational for two years now and brings together all ecosystem players, including media agencies. The goal of this approach, coordinated by IAB France (International Advertising Bureau), is to assess and promote responsible sites based on the quality of their content and the advertising practices used (cookie and browsing preference policies). This work resulted in a certification recognizing sites with the best practices in terms of editorial context, visibility of advertising campaigns, the fight against fraud, priority access to content and respect for personal data;
• Publicis Groupe has, for several years, been a member of the Coalition for Better Ads, which brings together all key players in the ecosystem (companies and trade organizations) around the common goal of improving online advertising standards. While it is clear that this finances many digital activities, it also has to better meet the expectations of consumers. One of the areas of work concerns the non-intrusive nature of advertising and the technical standards to be respected, notably regarding data protection.