Universal Registration Document 2025

4.1.4 Integration of sustainability issues into compensation

Since 2020, Publicis Groupe has included sustainability issues in the variable portion of the Chairman and Chief Executive Officer’s compensation, a compensation structure submitted each year to a shareholder vote. Variable compensation for long-term plans is described in Section 3.2.3. [ESRS 2 GOV-3-29 (a) to (e)] In 2025, two CSR criteria were included in the annual variable portion for the Chairman and Chief Executive Officer, each accounting for 10%:

• in social matters, women represented 46% in 2025 of the members of the Groupe’s main Executive Committees (Groupe Executive Committee, Management Committee, Executive Committee of the main countries excluding those based in the United States). The choice of this criterion was motivated by the need to advance gender equality, particularly at the highest levels of responsibility in the Groupe and its main subsidiaries. The 2025 target has been achieved and surpassed, with 46.5%;
• in terms of the environment, switch to 100% direct renewable energy by 2030, with an indicative checkpoint of 75% in 2025. The choice of this criterion was motivated by the digital nature of the activities and the need to use only renewable energy sources in all offices. The 2025 target has been achieved and surpassed, with 79.7%. [ESRS 2 GOV-3-29 (b) & (c)]

4.1.5 ESG risk management and mapping

Historically, ESG risks have been included in the Groupe’s major risk map  (Chapter 2 of this document), in particular risks relating to Talent and social issues, but also risks related to ethics, personal data and data security. These risks are also analyzed and monitored as part of the application of the French law on the Duty of Care (see Section 4.6). Topics are treated in-depth as part of the work of the Strategic, Environment and Social Committee. The same applies to the monitoring of the Company’s three main ESG priorities and related actions.

In the ESG mapping, five risks have been identified, some of which are aligned with the Groupe’s major risk mapping. No risk appeared to be very high and certain. [ESRS 2 GOV 5-36 (a) to (c)] These five CSR risks are:

• challenges in the management and protection of personal data in the context of artificial intelligence deployment (Chapter 2 and Section 4.3.11.7);
• data security breach in a context where cyber risks have increased (Chapter 2 and Section 4.3.11.8);
• deterioration in the well-being and working conditions of talent (Chapter 2 and Section 4.3.6.4);
• growing challenges on social equity issues (Chapter 2 and section 4.3.4);
• climate change challenges for advertising activities (see Section 4.2.2).

The results of this work on ESG risk mapping were presented to the Supervisory Board’s Audit Committee and ESG Committee in September 2023.

In 2025, Climate risks were revised, based on the work carried out in 2022. An ad hoc study was carried out, with the help of an external firm, on Climate-related risks, carried out with the Risk Management and Finance teams. The objective of this review was to re-examine the changes in physical risks – depending on the situation of offices and data centers in urban areas, and transition risks. Based on the work of the IPCC, two scenarios were selected: RCP 2.6 (stabilization at 1.8°C), and RCP 8.5 (+4°C scenario).

This work was shared with the Strategic, Environmental and Social Committee and the Audit Committee in September 2025. These elements were also considered to carry out the work for the Duty of Care risk mapping in 2025, presented to the Strategic, Environment and Social Committee in September 2025. [ESRS 2 GOV-5-36 (d)]

4.1.6 Sustainability-related internal controls

The structure of the sustainability-related internal control is based on several elements described in this chapter, in the sustainability reporting methodology, as well as in other chapters of this document, namely: [ESRS 2 IRO-1-53 (d)]

• the Groupe’s internal control and risk management system and procedures presented in Chapter 2, Sections 2.2.1, 2.2.2 and 2.2.4 and the sustainability reporting requirements are the same as those applied for financial reporting. The internal sustainability control system was structured in 2023. Key indicators were included in 2025, as part of a pilot phase, in the reviews carried out by FMC (Financial Monitoring Controls). The sustainability reporting processes are reassessed at the end of each exercise by integrating feedback from the various contributing teams, with a view to continuous improvement. The Groupe’s internal control and risk management framework is based on the COSO 2013 guidelines. [ESRS 2 GOV-5-36 (a) & (b)]
• the elements specific to sustainability reporting are explained in Section 4.1.2 (reporting methodology and processes). The 2025 CSR Reporting Comprehensive Guide is developed by the Groupe CSR Department and is shared with the FMC (Financial Monitoring Controls) and Risk Management teams. The Groupe CSR Department relies on a set of rules established by indicator for its verification stages at entity and country level and for consolidation; [ESRS 2 GOV-5 36 (a) & (d)]
• the Internal Audit teams have access to the reports and recommendations of the Statutory Auditors verifying the sustainability information;
• the work carried out by the Board Committees in Section 3.1.4. [ESRS 2 GOV-5-36 (d) & (e)]