The Anti-Bribery & Anti-Corruption Policy, part of the Janus Code of Ethics and Conduct, is rolled out at all levels of the organization and is based on the principle of zero tolerance for any form of bribery or corruption. All employees must comply with this Policy, as well as with all applicable anti-corruption laws. This Policy includes:
The policy is reviewed and updated periodically and was last updated at the beginning of 2026, following the 2024 risk mapping exercise. Updates to the policy, including additional practical guidance (DOs/DON'Ts), have reinforced the fact that certain vendors required a heightened degree of care and due diligence and that conflicts of interest in vendor selection must be avoided.
The Anti-Corruption Policy strictly prohibits all forms of bribery in keeping with principles emphasized in the OECD Anti-Bribery Convention and the 2003 UN Convention Against Corruption.
The Anti-Corruption Policy is accessible to all employees within the Anti-Bribery & Anti-Corruption chapter in Janus. In France, the anti-corruption policy is incorporated into the internal rules and, for this reason, has been the subject of the employee representative consultation procedure provided for in article L.1321-4 of the French Labor Code. It can be accessed by the general public in the “CSR Smart data” section of the Groupe’s website. [G1-1-10 (a), G1-3-20]
The corruption risk mapping exercise was updated in 2024 by the Internal Audit, Internal Control and Risk Management Department, in collaboration with the Compliance Department. The approach covers all of the Groupe’s activities and regions. The results were shared with the Secretary General and the Groupe Chief Financial Officer, and were presented to the Audit and Financial Risks Committee.
The Compliance Department relies on the mapping exercise to update the compliance program, policies, procedures, training and controls. The risk mapping exercise also is leveraged by the Compliance Department to help implement an accurate risk-based approach to assessing program enhancements and the impact of deployed resources.
Publicis Groupe has made an online anti-bribery & anti-corruption training program available to all employees. This training program includes a training course, is 25 minutes long and is designed to guide employees in preventing and detecting corruption risks by applying the Zero Tolerance principle. This training also covers how the whistleblowing system works. Specifically, the course highlights the rules around giving and receiving gifts and entertainment, working with public officials, and engaging third party representatives. The full course is mandatory for all employees, who are asked to complete it when they join the Groupe.
The Groupe also provided an online training course on the Groupe’s Whistleblowing Policy, and how to raise a good faith concern about unethical behavior in the workplace. It reminded employees of the importance of raising their voice when they witness unethical behavior, how to report good faith concerns, including anonymously, if preferred, and how the Groupe treats concerns (promptly, confidentially, and without retaliation).
Annual online training on anti-corruption and reporting ethics issues (“Reporting Ethics concerns”), the content of which may be updated to reflect updates to the anti-corruption program or the results of the corruption risk mapping, is made available to all employees, including those in positions of risk. [G1-1-10 (g), G1-3-21 (a)]
In-person training is also available for employees at increased risk of exposure to corruption. Legal and compliance teams at Groupe and country/regional levels host training sessions during the year to targeted employee audiences and aim to raise awareness and strengthen compliance with the Groupe’s rules around preventing and detecting corruption. [G1-1-10 (h)]
The Groupe Compliance Department regularly monitors attendance rates to both the online and in-person training programs and ensures the materials are effective at communicating the Groupe’s commitment to ethics.
The corruption risk mapping was finalized at the end of 2024; it is on this basis that the so-called risk categories are updated. In 2025, the online anti-corruption training and in-person training materials were updated to provide additional training information to help mitigate and address any potentially enhanced risks in keeping with the 2024 corruption risk map. For example, additional training materials were added to further clarify working with government entities and avoiding conflicts of interest. [G1-1-10 (h), G1-3-21 (b)]
