The aim of these rules of conduct is to provide the Groupe with strict rules and procedures for running our business worldwide in all fields: human resources management, ethics, financial management, individual responsibility. They are meant to prevent any illegal activity, in particular by ensuring that Groupe employees comply with laws and regulations which govern business conduct. The Groupe’s rules of conduct are also meant to prevent favoritism, misappropriation of funds, breach of trust, corruption, conflicts of interest or other misconduct and subject the Groupe and its employees to the highest standards in terms of integrity, ethics and compliance. They are designed to protect the Groupe’s data and know-how by establishing strict guidelines regarding confidentiality and good faith. They establish procedures for control and reporting by management of the Groupe and of the various networks of any breach of these policy rules. Certain policies have been made public.
This code was updated on May 25, 2022, with revisions scheduled once or twice a year. The last update was made in February 2024, and training sessions are arranged for all employees.
The Janus Code public policies are available on the Groupe’s website (www.publicisgroupe.com) in the “Corporate Social Responsibility” section, under “Library” then “Code of Conduct and Ethics.”
Janus provides detailed rules on stock market ethics in a specific chapter. The Groupe’s objective is to ensure compliance with the laws and regulations in force, as well as the recommendations issued by the AMF, in the area of risk management related to the holding, disclosure or possible use of insider information.
The purpose of the code is to:
These rules apply to any employee, corporate officer or executive corporate officer of the Company who has insider information, to their spouses and children, as well as to any person living in their household, until the information is publicly disclosed.
In addition, the Groupe has drawn up a list of employees, corporate officers and executive corporate officers with regular or occasional access to insider information and has set blackout periods during which these persons, and persons closely related to them, are prohibited from, on their own behalf or on behalf of the account of a third party, directly or indirectly, any transaction involving the Company’s securities, derivatives or other related financial instruments (unless authorized by the Company, pursuant to the regulations in force).
This specific chapter is regularly reviewed to adapt to legislative and regulatory changes and to take into account the recommendations of the AMF.
All Directors must comply with the laws and regulations that govern the position of Director of a société anonyme and, in particular, the rules with respect to:
The Board of Directors, in its internal rules and regulations, has set out strict rules on conflicts of interest: each Director must be able to perform his or her duties in complete independence from the other members of the Board.
Directors must perform their duties independently from each other and independently from any interests other than the Company's corporate interests.
Accordingly, Directors undertake to maintain their capacity to analyze, judge, decide and act independently and to resist all pressure, whether direct or indirect or internal or external to the Company, that may be exercised against them and, more broadly, not to seek or accept from the Company or its direct and/or indirect subsidiaries, or from any third party, any benefits that may be considered as compromising their independence.
