Universal Registration Document 2024

2.2.3.2 Regular monitoring of the internal control framework

Publicis Groupe has set up:

• key corporate controls over financial and non-financial reporting (consolidation, treasury, tax, legal, etc.), which are reviewed annually through internal control.
• a program called Financial Monitoring Controls (FMC), implemented in all Groupe entities and based on a list of key controls for the main processes contributing to financial and non-financial reporting. Their implementation is monitored at two levels:
  • a quarterly self-assessment, submitted by all Groupe entities via a common tool, which contributes to accountability and transparency regarding the effectiveness of controls,
  • teams dedicated to FMC reviews are located at regional level. These teams have a reporting line to the Groupe’s Internal Audit, Risk Management and Internal Control Department, which oversees them, coordinates their work and compiles their results, and functionally report to the Finance Department of each region. These teams follow a systematic review plan covering about 70% of the Groupe’s consolidated revenue.

2.2.3.3 Monitoring by the Legal and Compliance departments

The Groupe Legal Department, headed by the Groupe General Counsel, reports to the Secretary General. This department relies on a network of legal managers covering all of the Groupe’s activities and regions. They assist the Groupe’s operational departments to ensure the compliance of their activities with the laws and regulations in force, while respecting the policies and procedures of “Janus.”

The Compliance Department reports to the Groupe’s Chief Compliance Officer, who reports to the Secretary General. Its objectives are to promote an ethical culture within the Groupe and to design, deploy and monitor the implementation of compliance programs in all Groupe entities.

This department relies on a network of compliance officers operating at the local level. Under its supervision, they are responsible for coordinating and ensuring the effective deployment of compliance programs within their scope (see Section 4.4.3 of this document).

2.2.3.4 Process for preparing non- financial information⁽¹⁾

Since May 2024, the Chief Impact Officer has been responsible for overseeing Corporate Social Responsibility (CSR). The Chief Impact Officer keeps the Audit and Financial Risks Committee and the Strategic, Environmental, and Social Committee informed about regulatory changes in sustainability reporting, project progress, and the activities conducted with external sustainability auditors.

The Groupe's CSR Department is responsible for non-financial reporting and collaborates closely with other departments, particularly through the CSR Steering Committee.

In alignment with the requirements of the CSRD and ESRS, the CSR Department, supported by a cross-functional project team, has developed the 'CSR Reporting Comprehensive Guide.' This internal framework for sustainability reporting has been revised and finalized. It encompasses the definition of both quantitative and qualitative indicators, calculation rules, and the organization of data controls. The guide aims to structure data production and consolidation processes at every level of the Company and across all reporting areas, facilitating effective communication of the reporting results.

Data collection for sustainability reporting is aligned with that for financial reporting. All of the quantitative data and qualitative information is checked and analyzed by the Groupe CSR Department, which compiles the consolidated reporting for the whole Groupe.

Sustainability reporting is done with the help of CSR Managers, CSR or Sustainability Champions in agencies, and with the support of teams from the shared service centers (Re:Sources) involved upstream of the reporting, and throughout the year.

New control points will be included in the reviews in carried out by the Financial Monitoring Controls (FMC) and internal audit in 2025.

2.2.4 Risk management framework⁽²⁾

In coordination with Executive Management, the business management teams of the countries/regions/business lines as well as the shared service centers are heavily involved in monitoring risks facing the Groupe. They continually analyze the Groupe’s exposure to the loss of significant contracts, to risks of conflicts of interest and to changes in contractual clauses.

The Groupe’s Legal Department regularly monitors risks related to litigation within the Groupe. A summary of any significant legal disputes, as well as an estimate of their potential impacts, are presented to the Groupe’s Executive Management four times per year. The main legal disputes and current or finalized investigations, where relevant, are also discussed at each Audit and Financial Risks Committee meeting.