Universal Registration Document 2025

4.4.2 Janus: policies and ethical principles in business conduct

Janus is the Groupe’s Code of Conduct and Ethics and applies to all managers and their teams. It consists of a code of conduct and detailed operating rules. This Code applies to all employees without exception. In 2025, 95% of the Groupe’s employees received training in the Janus Code and its contents. Training takes various forms: online training in Marcel, awareness-raising sessions during programs for new employees, and more specific internal sessions for certain more exposed positions. In the induction programs, Janus is explained as part of the presentation of the Groupe and its activities. The key principles are detailed in particular regarding the standards of behavior of managers and teams, and the rules of operation to comply with fair practices. These include the “Zero Tolerance” principle in terms of discrimination, harassment, and violence at work; rules regarding conflicts of interest, fraud, and the prevention and combating of corruption; data protection; the key points of the HR policy; and a reminder of the major principles adhered to by the Groupe, such as the United Nations Global Compact. [G1-1-7, G1-1-8, G1-1-9]

In terms of business, one of the Groupe’s historic principles is its refusal to take part in partisan communications campaigns of any kind. The Groupe refuses to work for political parties, cults or ideological propaganda organizations, and refuses any request for funding, contribution or free support.

Two mandatory modules were launched in 2025: Generative AI Ethics & Responsible Use - completed by 62% of employees; and Powering Sustainability - completed by 61% of employees. These rates are normal for a first year.

Several extracts from Janus are available on the Groupe’s website, in the CSR section, at the following address: www.publicisgroupe-csr-smart-data.com/fr/links.

4.4.2.1 Centralized whistleblowing system

Employees, suppliers and all other parties may report any concern related to a potential violation of laws or company policies on fraud, corruption, harassment, discrimination or any other ethics concerns, as stated in the Janus Code of Conduct and Ethics and the Reporting Concerns, or “whistleblowing” policy. This policy and the system for reporting concerns are accessible to all employees and publicly available in the “CSR Smart data” section of the Groupe’s corporate website. [G1-1-10 (c) & (e)]

Each year, all Groupe employees receive a message from the Secretary General informing them of the existence of the whistleblowing system, accompanied by a video reminding them of its operation and with examples of behavior contrary to the Company’s rules. Locally in the countries, the HR/Talent teams also disseminate a similar message, with contextual information allowing employees to understand why and how to use it. The external Ethics Concerns platform, available at https://publicis.whispli.com/lp/ethicsconcerns, makes it possible to receive all types of reports, whether internal or external. [G1-1-10 (e)] All whistleblowing reports received are processed, even those sent anonymously, if they are sufficiently precise and substantiated. They are dealt with by the Compliance Department, with support from the Internal Audit Department, the Legal Department or the Human Resources Department under the supervision of the Secretary General. Investigations are carried out by the Internal Audit Department or by a lawyer, using the appropriate resources depending the subject in question, while maintaining strict confidentiality. Whistleblower communications are protected by confidentiality, and any form of retaliation against a whistleblower acting in good faith is strictly prohibited. [G1-1-10 (c)]

In 2025, 197 whistleblowing reports were received and dealt with, of which 84% were internal reports. 74% of the cases concerned HR topics, mainly related to internal operations. The increase in the number of alerts is due to strengthened internal communication and the introduction of the new Ethics Concerns platform – https://publicis.whispli.com/lp/ethicsconcerns. The results of the investigations carried out are communicated to Executive Management and a report is provided to each Audit and Financial Risks Committee.