The Emeritus Chairman is not a corporate officer. However, he is subject to the same rules of confidentiality and ethics as those applicable to Directors, including the rules relating to the prevention of market abuse. As such, he is subject to compliance, with the obligations to abstain from trading in Publicis Groupe SA shares during “blackout periods.”
Similarly, in the event of a conflict of interest, even a potential one, in which the Emeritus Chairman may be directly or indirectly involved, the latter must also refrain from attending or participating in the discussions concerning the corresponding deliberation, or requesting any document or information in any form whatsoever relating to the subject in question.
It is specified that Mr. Maurice Lévy is not compensated for his role as Emeritus Chairman.
The Groupe has a set of rules governing its behavior and ethics under the name “Janus”. It is applicable to all of the Groupe’s hierarchical levels and sets out the rules of conduct for operations: “The Publicis way to behave and to operate”. It is regularly updated, distributed across all internal networks and is available in seven languages.
Janus includes the rules and principles related to ethics, Corporate Social Responsibility, compliance with regulatory and legal frameworks, governance, communication, conducting business and client relations, human resources management, protecting the Groupe’s brand names, other intellectual property rights and financial and accounting management, as well as rules governing mergers and acquisitions, investments, restructuring and purchasing policies.
The guidelines include a Code of Conduct and Ethics applying to all Groupe employees with specific rules for the main executives. The values embodied by Publicis are clearly outlined there, starting with our commitment to our clients and respect for individuals and their diversity.
The aim of these rules of conduct is to provide the Groupe with strict rules and procedures for running our business worldwide in all fields: human resources management, ethics, financial management, individual responsibility. They are meant to prevent any illegal activity, in particular by ensuring that Groupe employees comply with laws and regulations which govern business conduct. The Groupe’s rules of conduct are also meant to prevent favoritism, misappropriation of funds, breach of trust, corruption, conflicts of interest or other misconduct and subject the Groupe and its employees to the highest standards in terms of integrity, ethics and compliance. They are designed to protect the Groupe’s data and know-how by establishing strict guidelines regarding confidentiality and good faith. They establish procedures for control and reporting by management of the Groupe and of the various networks of any breach of these policy rules. Certain policies have been made public.
Janus is regularly reviewed. In parallel with the work to update this code, a new presentation of the Groupe’s Code of Ethics and Conduct was circulated in December 2025. This document, intended to be shared internally and externally, brings together the principles and values that guide the Groupe, as set out in the Janus Code. This Code reaffirms Publicis’ commitment to its clients, partners and talents. Training courses are organized for all employees to encourage the adoption of these principles and to ensure the uniform application of the Groupe’s rules of ethics and conduct.
The Janus Code public policies are available on the Groupe’s website (www.publicisgroupe.com) in the “Corporate Social Responsibility” section, under “Library” then “Code of Conduct and Ethics”.
Janus provides detailed rules on stock market ethics in a specific chapter. The Groupe’s objective is to ensure compliance with the laws and regulations in force, as well as the recommendations issued by the AMF, in the area of risk management related to the holding, disclosure or possible use of insider information.
The purpose of the code is to:
These rules apply to any employee, corporate officer or executive corporate officer of the Company who has insider information, as well as to persons closely related to them within the meaning of the MAR regulation, until the information is publicly disclosed.
