Universal Registration Document 2025

4.1.9 Double materiality analysis – impact and financial

The double materiality analysis is based on the premise of examining, on the one hand, financial materiality, with the impact of the deterioration of societal and environmental conditions on the Company’s activity and its financial impacts, and, on the other hand, the materiality of impact, with the measurement of the impact of the Company’s activities under these same conditions.

The work was carried out with the help of Salterbaxter⁽¹⁾ at Groupe level in several stages, with the involvement of the Finance and Risk Management teams (see ESG risk mapping, Section 4.1.5). The starting point was the key CSR issues for Publicis Groupe, the same issues that formed the basis of the ESG risk mapping. The work on ESG risks was also reconciled with the work carried out in 2025 on the risks related to the Duty of Care Plan (Section 4.6).

The scope taken into account is that of the Company’s own operations, as well as its commercial relations with,

1. its direct upstream suppliers;
2. its downstream clients, with whom the relationship is direct;
3. consumers and end-users, with whom the downstream relationship is indirect, as they are our clients’ customers;
4. other indirect relationships are established mainly with the media and communication platforms, with whom the relationship is indirect because it is carried out on behalf of clients; and with communities and civil society organizations. [ESRS 2 SBM-3-48 (b) to (g), ESRS 2 IRO-1-53 (b) i, ii, iii]

The work steps were as follows:

• contextual and sectoral, documentary and regulatory analysis. The literature review took into account:
  • regulatory aspects and interpretation of legislation,
  • the point of view of professional organizations,
  • as well as the review of the criticisms leveled at the communications industry by associations and activists;
• integration of the 2025 update of the Climate risk mapping;
• integration of the 2025 update of the Groupe’s major risks mapping;
• cross-checking of work with that of ESG risk mapping;
• qualitative interviews with clients from different sectors in several countries including the United States, the United Kingdom and France;
• qualitative interviews with some ESG investors;
• qualitative internal interviews with employees, supplemented by webinars in four countries in 2023 (the United States, France, India and the United Kingdom), and repeated in 2024 in France and the United Kingdom to deepen the opportunity component. These interviews were supplemented by an internal survey beginning - and ending - in 2024 to which 350 employees familiar with CSR responded, using the internal Marcel Intelligence platform;
• in 2025, all of this work was resumed in order to align with the approach recommended by EFRAG⁽²⁾, requiring a finer and more detailed level of granularity. This analysis took into account the various activities and regional locations This work did not reveal any significant findings in relation to 2024;
• a new Impacts, Risks, and Opportunities (IROs) rating exercise was carried out with internal Subject Matter Experts (SME), to finalize a new presentation. The latter, illustrated by an infographic, shows their positioning in the value chain: Upstream - Operations/ Activities - Downstream;
• Publicis Groupe does not have a Social and Environmental Committee (CSE) at Groupe level, as the Groupe Works Council in France does not have the attributes of a CSE. [ESRS 2 IRO-1-53 (a) & (b) i to iv; ESRS 2 IRO-1-53 (e) to (h)]

The double materiality analysis prioritized IRO (impacts, risks and opportunities) based on:

• the four-level severity of impacts scale (1-low, 2-moderate, 3-high, 4-major) used to prioritize the Groupe’s risks (see Section 2.2.4) ;
• the four-level probability of occurrence scale (1-rare, 2-possible, 3-probable, 4-certain) used to prioritize the Groupe’s risks (see Section 2.2.4) ;
• the time frame used is presented in the table below based on the concepts of short term (one year), medium term (between one and three years) or long term (more than three years). [ESRS 2 BP-48 (d) & (e); ESRS 2 IRO-1-53 (c) i to iii]