Universal Registration Document 2025

4.1 GENERAL INFORMATION

4.1.1 General basis for preparation

The European Directive, the CSRD (Corporate Sustainability Reporting Directive) and ESRS (European Sustainability Reporting Standards), are primarily intended to bring non-financial reporting to the same level of requirements as financial reporting, to give a more complete understanding of the Company’s activities and its impacts. This Directive also aims to harmonize and to improve the quality of sustainability information published by European companies. Pursuant to the "Quick Fix" delegated act no. 2025/1416 adopted by the European Commission on July 11, 2025, Publicis Groupe has applied the transitional measures planned for the 2025 financial year.

The Groupe continued to improve its non-financial reporting to comply with the regulatory requirements set by ESRS, as applicable on the date the sustainability report was prepared, based on the data and information available. The use of scope limitations is mentioned on a case-by-case basis for certain data, as specified in the contextual elements.

2025 is the second year of implementation, in a context where the European regulator has already announced future simplification; the Groupe seeks to improve its sustainability reporting in line with additional recommendations, positions, or interpretations as soon as they become available. The regulator provides for the possibility of changing the scope over the first years of implementation; this option is used for a limited number of indicators. In December 2025, the European Trialogue bodies (European Commission, Council of Europe, European Parliament) agreed to simplify the CSRD and CSDDD (Corporate Sustainability Due Diligence Directive); once confirmed, this change will have to be translated into national law.

The sustainability report covers all Publicis Groupe subsidiaries worldwide, aligned with the consolidated scope of financial reporting, from January 1 to December 31, 2025, including companies accounted for using the equity method. [ESRS 2 BP-1-5 (b) i] Any exclusions are indicated in the scope for the indicators concerned (see Section 4.1.2). Companies acquired within the last six months as of December 31, 2025 are included in all social indicators, but not in the environmental indicators.

The CSR Steering Committee, in place since 2009, is the internal forum for working on the implementation of regulatory changes. Joint work is carried out between departments throughout the year. The double materiality analysis (DMA) has been revised to incorporate the EFRAG methodology published in 2024, calling for a more detailed analysis of each impact-risk-opportunity (IROs). A regular progress report was presented to the Groupe’s Secretary General and Chief Impact Officer. This work confirmed the four ESRS standards considered as non-material:

• ESRS E2 - Pollution: with regard to the double materiality analysis and the type of intellectual services offered to the Groupe’s clients, pollution issues do not appear to be applicable. This does not exempt the Company from measuring its waste and type of waste or improving its waste sorting. Since 2009, the Company has been measuring the volume of its waste and e-waste every year in order to reduce it and promote efficient recycling. The Groupe questions its suppliers on this matter as part of their CSR assessments. In addition, the Groupe annually monitors the commitments of its major clients in terms of the environment, in particular their climate trajectory and the reduction of their impacts. [ESRS 2 IRO- 2-58]
• ESRS E3 - Water and marine resources: the double materiality analysis does not identify this topic as material, which is consistent with the Company’s intellectual services activities. However, the quantities of water consumed in offices around the world have been traced since 2009, and the objective remains to limit the use of this resource. The Groupe also asks its suppliers about their impacts on their management of water resources, in particular high-consuming activities such as data centers and the cloud. [ESRS 2 IRO-2-58]
• ESRS E4 - Biodiversity and ecosystems: given that it provides intellectual services activities to companies, the Groupe’s double materiality analysis does not identify this as a major topic. However, aware that these are natural dimensions that need to be better understood, the Groupe carried out an initial biodiversity footprint analysis in 2023. This work did not reveal any significant impacts. [ESRS 2 IRO-2-58]
• ESRS S3 - Affected communities: the Groupe has historically been very committed to local communities in the countries and cities where the teams work. However, the double materiality analysis did not identify this topic as material. The Groupe will continue to analyze the actions it carries out in favor of communities, in particular its societal commitments and actions promoting public interest causes. [ESRS 2 IRO-2-58]