Universal Registration Document 2025

ESRS S2 – Value chain workers

4.3 Social: fundamental human rights, impact & equity

ESRS S2 – Value chain workers

ESRS S2 VALUE CHAIN WORKERS

The European CSRD regulations and the ESRS require companies to explain their interactions with different social groups. These interactions vary depending on the industry, business sector and company. In this respect, given that it provides intellectual services activities to companies and in view of the priorities resulting from the double materiality analysis, Publicis Groupe focuses on employees in the so-called supply chain.

4.3.10 Focus on employees in the supply chain

For Publicis Groupe, employees in the upstream value chain are mainly the employees of our suppliers, namely:

  • those seconded to our offices as part of an on-site service;
  • those who regularly work with our teams on projects for our clients;
  • those working on products and services purchased by the Groupe and its subsidiaries. [SBM-3-11 (a)]

The ESRS SBM-3-11 requirements on value chain impacts, including the supply chain, are the subject of an analytical work by the Procurement Department. The objective is to identify, by category of supplier, the structure of the relations between the various partners in each value chain to identify the due diligence needed to specify the Company’s role of influence in order to avoid any significant adverse impacts that could occur. Given the volume of purchases and their critical nature for the company’s activities, IT suppliers seem to require more detailed analysis, both in social and environmental terms. [SBM-3-11 (c)]

The CSR for Business Guidelines highlight the Company’s desire to build a partnership with its suppliers in order to ensure an attractive business relationship for all parties. As part of multi-year contracts, annual reviews are scheduled to discuss CSR indicators and their progress, covering both social and environmental issues, or participation in social innovation projects, such as Working With Cancer. See Section 4.4.4.2 on the “Enhanced ESG Program.” [S3 SBM-3-11 (d)]

In 2024 and 2025, a pilot project focused on the situation of our suppliers’ employees in the "Facilities Management" category, namely: reception, security, catering, cleaning. The special feature of these employees is that they are permanently on our premises and interact with our employees on a daily basis.

4.3.10.1 Procurement-related impacts, risks and opportunities – in brief
Procurement-related impacts, risks and opportunities – in brief
IRO/Score/Time frame Definition of IRO Policies & ad hoc work Major actions [S2-30; S2-31; S2-32 (a)&(b)& (c)&(d); S2-33 (a)&(b)&(c); S2-34 (a)&(b)] Objective
IRO

/Score/Time frame

Negative impacts

IRO 12

High

ST/MT/LT

Definition of IRO

Non-compliance with human and labor rights (the first four points of the CSR For Business Guidelines) could alter the situation of more exposed or fragile employees at certain suppliers

Policies &

ad hoc

work

  • Janus – Values
  • CSR for Business Guidelines

Major actions [S2-30; S2-31; S2-32 (a)&(b)& (c)&(d); S2-33 (a)&(b)&(c); S2-34 (a)&(b)]

  • Social audits were carried out in the Facilities Management category, as the employees of these suppliers were physically in the Groupe’s offices (see Section 4.3.10.3))
  • Suppliers included in the ESG Enhanced Program must commit to taking action in social and environmental areas, and share their quantified progress with Publicis
  • As part of Due Diligence (see Section 4.4.4.2), in the financial analysis of the relationship with the supplier, particular attention is paid to the weight that the Groupe represents for its suppliers. Above 20%, ad hoc monitoring is carried out by buyers

Objective

100% of Significant suppliers in compliance with the Enhanced ESG Program in 2030 (see section 4.4.4)

IROs: impacts - risks - opportunities

Score: Low, Medium, High, Major

Time frame: ST: short-term; MT: medium term; LT: long-term

4.3.10.2 Responsible Procurement Policy CSR for Business Guidelines

The CSR for Business Guidelines Policy, the Code of Conduct for suppliers, is a contractual appendix which is binding on the supplier regardless of the country. This public document (on the Groupe’s website) establishes 17 key points and reciprocal commitments in terms of sustainability, relating to social, ethical and environmental issues. This policy is reviewed annually by the Groupe Procurement and Groupe CSR Departments in order to adjust the levels of requirements and take into account regulatory changes. This policy indicates a "Zero Tolerance" with regard to forced labor or modern slavery or child labor. This same “zero tolerance” is applied to situations of discrimination and harassment in all their forms. This policy also contains the channels available for whistleblowers, including the external and independent platform. [S2-1-16, S2-1-18]

The 17 points are as follows:

  1. CSR commitment – Human rights section;
  2. Business ethics – Labor law & Fundamental Freedoms;
  3. Anti-corruption and fight against fraud;