Universal Registration Document 2025

4.4 Governance, business ethics and responsible marketing

4 Sustainability

4.4 Governance, business ethics and responsible marketing

4.4 GOVERNANCE, BUSINESS ETHICS AND RESPONSIBLE MARKETING

In this section, the Groupe has chosen to focus on two key aspects that are material for the proper conduct of the Company’s activities: business ethics, an imperative that applies to everyone without exception, and marketing and responsible technology, with a more relevant business line approach.

ESRS G1 BUSINESS CONDUCT AND ETHICS

The role of the administrative, management and supervisory bodies

Publicis Groupe is a French limited liability company (société anonyme) with a Board of Directors. The Chair and Chief Executive Officer is assisted by an Executive Committee and a Management Committee. The functioning of the Company’s governance bodies and operational management bodies are described in Chapter 3.1 of this document. Roles and responsibilities in terms of sustainability are outlined in Section 4.1.3 on CSR Governance. [G1 ESRS 2 GOV-1-5 (a)]

4.4.1 The Groupe’s commitments

Publicis Groupe was founded in 1926 on the basis of strong ethical principles, regularly reaffirmed by the Chairman of the Groupe. The Groupe’s Janus Code of Conduct and Ethics is the backbone of the way in which the company intends to conduct its development. Janus applies to all employees, including managers and executives. This Code is updated each year and supplemented by a detailed procedure code. Janus specifies the way in which relationships must be established with clients, suppliers, civil society and other third parties (see Section 4.4.2 below).

Publicis was the first communication group to join the United Nations Global Compact in 2003, and to promote its Ten Principles. Then the Groupe signed the Seven Key Principles of the United Nations WEPs (Women Empowerment Principles) and decided to follow the United Nations Sustainable Development Goals for a fairer world.

4.4.1.1 Impacts, risks and opportunities – in brief
Impacts, risks and opportunities – in brief

IRO/Score/

Time frame.

Definition of IRO Policies & ad hoc work Major actions Objectives
RisksIRO 18 HightST/MT/LT

Risks

IRO 18

Hight

ST/MT/LT

Definition of IRO

The client portfolio can have an impact on the attractiveness of talent and on the reputation of the Company

Risks

IRO 18

Hight

ST/MT/LT

Policies &

ad hoc work

Janus - Values

Risks

IRO 18

Hight

ST/MT/LT

Major actions

Publicis has always supported its clients in periods of strong transition, as is the case today in ecological or technological matters with AI. The Groupe’s agencies help them to develop their strategic, marketing and digital transformation.

Risks

IRO 18

Hight

ST/MT/LT

Objectives

Unquantified

RisksIRO 19 Hight ST/MT/LT

Risks

IRO 19

Hight 

ST/MT/LT

Definition of IRO

Legal, financial and reputational risks could be caused by unethical conduct, such as corruption, bribery and fraud

Risks

IRO 19

Hight 

ST/MT/LT

Policies &

ad hoc work
  • Janus - Values
  • Janus – AntiBribery & Anti-Corruption Policy
  • Janus – Compliance & Ethics

Risks

IRO 19

Hight 

ST/MT/LT

Major actions

  • Employee training in ethical rules is a prerequisite, indicating clear limits to all employees; the annual updates of policies (12 languages) are also an opportunity to remind people of the fundamental principles
  • All employees undergo mandatory anti-corruption training each year, with practical cases
  • The internal control and internal audit measures in place enable the application of policies to be monitored

Risks

IRO 19

Hight 

ST/MT/LT

Objectives

90% of employees trained each year

IRO/Score/

Time frame.

RisksIRO 20

Entity Specific

Hight ST/MT/LT

Definition of IRO

In a digital world, cyber risks are growing and can impact the smooth running of business activities, as well as intellectual property related to content.

Policies &

ad hoc work
  • Janus - Values
  • Janus - Intellectual Property
  • Cybersecurity risk mapping

Major actions

The protection of intellectual property is one of the values shared in the Janus training on values. Mandatory training on data protection and security addresses cyber risks and the need to secure all stages of work processes

Objectives

90% of employees trained every year

IRO/Score/

Time frame.

RisksIRO 21

Entity Specific

Hight ST/MT/LT

Definition of IRO

Internal IT systems and the major Cloud partners on which the Groupe depends can be directly attacked or impacted, thus undermining business continuity for clients.

Policies &

ad hoc work
  • Janus - Data Security
  • Business continuity plan
  • Cybersecurity risk mapping

Major actions

  • IT teams are regularly trained to test situations involving temporary business disruptions, in order to verify that alternative options for ensuring business continuity are operational.
  • ISO 27001 certification covers 100% of GSO teams

Objectives

100% of IT teams trained each year