Publicis Groupe completes an assessment of its third parties and performs anti-corruption-specific due diligence using a risk-based approach. Publicis Groupe does not work with any third party that presents a risk of corruption or that does not agree to comply with anti-corruption laws and the Groupe’s anti-corruption policy. In this regard, suppliers are assessed and verified before the contract is signed. For more details on the Groupe’s third-party assessment policy in procurement (see Section 4.3.10.2).
Janus also includes an accounting policies and procedures framework applicable to the Groupe and all of its subsidiaries.
These accounting policies and procedures are intended to ensure that the books, records and accounts are not used to conceal acts of corruption. Control tests are carried out by the Financial Monitoring Controls (FMC) teams periodically to ensure compliance with the Groupe’s accounting rules.
The Groupe’s anti-corruption compliance program includes regular monitoring by the Compliance Department and Internal Audit teams, who conduct audits in the agencies throughout the year. The Internal Audit, Risk Management and Internal Control Department interacts regularly with the Compliance Department in order to optimize audit and internal control practices and contribute to the anti-corruption program.
Accounting controls dedicated to the prevention of corruption are also periodically implemented by FMC. Audits are carried out by Internal Audit or external auditors as part of the certification audits of the financial statements provided for in article L. 823-9 of the French Commercial Code (Code de commerce).
Internal Audit reports on its work, including on fraud and corruption prevention, to Executive Management, and regular reports are presented to the Audit and Financial Risks Committee. The Internal Audit Department also shares its work with the Compliance Department to influence decisions aimed at updating the policies, processes and procedures of the anti-corruption compliance program. [G1-3-18 (c)]
Employees, clients, suppliers and third parties can report ethics concerns relating to violations of the Anti-Bribery & Anti-Corruption Policy and/ or applicable anti-corruption laws using the Ethics Concerns platform, hosted by an external service provider, and available at https://publicis.whispli.com/lp/ethicsconcerns.
Alerts can be made anonymously and all alerts are treated promptly and confidentially, as described in the Reporting Ethics Concerns policy. Whistleblowing reports are received by the Secretary General and Chief Compliance Officer, and reviewed by the Compliance Department or the Internal Audit Department, under the responsibility direction of the Secretary General (see Section 4.4.2.1). [G1-1-10 (c) & (e), G1-1-18 (b) & (c)]
[G1-4-24 (a), G1-5-25 (a) à (d)]
| 2024 | 2025 | |
|---|---|---|
| Number of convictions for violation of anti-corruption laws | Number of convictions for violation of anti-corruption laws 2024 – |
Number of convictions for violation of anti-corruption laws 2025 – |
| Amount of fines for violation of anti-corruption laws | Amount of fines for violation of anti-corruption laws 2024 – |
Amount of fines for violation of anti-corruption laws 2025 – |
Any employee who violates the Anti-Bribery & Anti-corruption policy may be subject to disciplinary action, the result of which may be severe penalties up to and including dismissal. Immediate measures may be taken should suppliers contravene this Policy.
Some assignments may involve lobbying and strategies to influence decision-makers. The lobbying teams operate in compliance with the laws and the Groupe’s rules, particularly concerning combating conflicts of interest and anti-corruption. In accordance with legal obligations and best practices, the teams concerned are identified in the digital repertoire of representatives of interests managed by the High Authority for the Transparency of Public Life in France (HATVP).
Publicis Groupe did not lobby on its own behalf in 2025.
Publicis has the historical principle of refusing to work for partisan campaigns (political parties, cults or ideological organizations). The Company does not financially or otherwise support such organizations. This clear and public position is included in Janus, the Groupe’s Code of Conduct and Ethics, and applies everywhere. [G1-5-28 (a) & (b), G1-5-29]
