Universal Registration Document 2025

4.6 Duty of care plan

4 Sustainability

4.6 Duty of care plan

4.6 DUTY OF CARE PLAN

In accordance with law no. 2017-399 of March 27, 2017 on the duty of care required for parent companies and contracting companies, transposed in articles L. 225-102-41 and L. 225-102-2 of the French Commercial Code, Publicis Groupe has drafted and implemented a plan comprising duty of care measures for the identification of risks and prevention of serious infringements in the areas of human rights and fundamental freedoms, health, personal safety and the environment resulting from the Company’s activities and those of the companies it directly or indirectly controls, as well as the activities of subcontractors or suppliers.

This plan includes:

  • a mapping of risks for their identification, analysis and prioritization;
  • procedures for assessment of the situation of subsidiaries, subcontractors or suppliers with which the Groupe has an established business relationship, with regard to risk mapping;
  • appropriate actions to mitigate risks or prevent serious harm, where applicable;
  • a mechanism for alerting and collecting alerts relating to the existence or occurrence of risks, established in consultation with labor unions;
  • a system for monitoring the measures implemented and assessing their effectiveness.

4.6.1 Governance and scope

Risks identified under the duty of care are managed and controlled in accordance with the general policy on internal risk management and control, as outlined in Section 2.2. The management, internal control, and monitoring framework applicable to all of the Groupe’s financial and non-financial risks also covers risks related to the duty of care.

The Board’s Strategic, Environmental and Social Committee ensures compliance with the Company’s Duty of Care obligations, pursuant to article 11 of the Board’s internal rules and regulations. As such, it reviews the Groupe’s Duty of Care Plan at least once a year and is informed of the actions implemented. Committee members are regularly made aware of regulatory changes in Duty of Care, particularly in Europe.

The mapping of the Duty of Care risks and the progress of the actions implemented under the Duty of Care Plan were presented to the Strategic, Environmental and Social Committee and the Board of Directors in September 2025.

The Duty of Care Plan covers all the activities of Publicis Groupe and its subsidiaries, as well as those of its subcontractors and suppliers with which it has an established commercial relationship.

4.6.2 Risk identification and methodology

The purpose of the Duty of Care risk mapping is to identify, analyse and prioritize the risks and serious violations related to the activity of the Company, its subsidiaries and its suppliers with regard to human rights and fundamental freedoms, personal health and safety and environmental matters. It is prepared by the Internal Audit and Risk Department according to the common risk mapping methodology introduced by the Groupe as described in Section 2.2.4.

More specifically, risk mapping under the duty of care is developed based on a two-step analysis of activities:

  • a preliminary document review identifies actual and potential risks and delineates the general areas where risks are most severe and most likely to occur; and,
  • based on these initial findings, an in-depth assessment is conducted through interviews and working groups in the areas where risks have been identified as most severe and most likely to occur.

Risks are prioritized according to their severity and likelihood so that those identified as the most serious and most likely to occur are addressed first.

A first mapping was carried out in 2017. It has been regularly updated since then. The completion of the ESG risk mapping in 2023 covered certain aspects of the Duty of Care. The risk mapping related to the Duty of Care was reviewed in July 2024 by Groupe experts in the various areas of expertise concerned. This review confirmed the broad outlines of the previous mapping; no new risks were identified.

As the core of the Company’s activity is business services, the mapping mainly refers to risks relating to human rights and fundamental freedoms, on the one hand, and risks related to personal health and safety, on the other hand; risks related to the environment are low in terms of both probability and potential impact.