In accordance with law No. 2017-399 of March 27, 2017 on the duty of care required for parent companies and contracting companies, transposed in article L. 225-102-4 of the French Commercial Code, Publicis Groupe has drafted and implemented a plan comprising duty of care measures for the identification of risks and prevention of serious infringements in the areas of human rights and fundamental freedoms, health, personal safety and the environment resulting from the Company’s activities and those of the companies it directly or indirectly controls, as well as the activities of subcontractors or suppliers.
This plan includes:
At the operational level, a Steering Committee dedicated to the Duty of Care Plan was set up in 2017. It is composed of members representing the Internal Audit, Risk Management and Internal Control Department, the CSR Department, the Purchasing Department, the Human Resources Department and the Legal Department. This Committee reports to the Groupe’s Secretary General. The Steering Committee meets annually, and topical working sessions are organized in smaller committees.
At the Board level, the Strategic, Environmental and Social Committee ensures compliance with the Company’s Duty of Care obligations, pursuant to article 11 of the Board’s internal rules and regulations. As such, it reviews the Groupe’s Duty of Care Plan at least once a year and is informed of the actions implemented. Committee members are regularly made aware of regulatory changes in Duty of Care, particularly in Europe.
The mapping of the Duty of Care risks and the progress of the actions implemented under the Duty of Care Plan were presented to the Strategic, Environmental and Social Committee and the Board of Directors in September 2024.
The Duty of Care Plan covers all the activities of Publicis Groupe and its subsidiaries, as well as those of its subcontractors and suppliers with which it has an established commercial relationship.
The purpose of the Duty of Care risk mapping is to identify and prioritize the risks and serious violations related to the activity of the Company, its subsidiaries and its suppliers with regard to human rights and fundamental freedoms, personal health and safety and environmental matters. It is prepared by the Internal Audit and Risk Department according to the common risk mapping methodology introduced by the Groupe as described in Chapter 2.
A first mapping was carried out in 2017. It has been regularly updated since then. The completion of the ESG risk mapping in 2023 covered certain aspects of the Duty of Care. It confirmed the absence of serious risk in this area. The risk mapping related to the Duty of Care was reviewed in July 2024 by Groupe experts in the various areas of expertise concerned. This review confirmed the broad outlines of the previous mapping; no new risks were identified.
As the core of the Company’s activity is business services, the mapping mainly refers to risks relating to human rights and fundamental freedoms, on the one hand, and risks related to personal health and safety, on the other hand; risks related to the environment are low in terms of both probability and potential impact.
The risk mapping, carried out as part of the Duty of Care, did not detect any risk or serious violation of human rights and fundamental freedoms, personal health and safety, or the environment.
However, even in the absence of risks or serious harm, certain risks described below require special attention and are closely monitored by the Groupe.
