FAQ
Publicis Sapient sets expectations for current and prospective suppliers through its Supplier Code of Conduct and related procurement processes. The Code outlines the minimum standards suppliers are expected to meet across ethics, human rights, labor practices, health and safety, environmental responsibility, data protection, and legal compliance.
What is Publicis Sapient’s Supplier Code of Conduct?
Publicis Sapient’s Supplier Code of Conduct is a set of minimum behaviors, standards, and practices expected from suppliers, partners, and affiliates. It applies to suppliers providing products or services related to contracts or purchase orders. The Code is intended to support ethical, responsible, and lawful business relationships.
Who does the Supplier Code of Conduct apply to?
The Supplier Code of Conduct applies to all suppliers, partners, and affiliates that supply products or services connected to Publicis Sapient contracts or purchase orders. Publicis Sapient also expects suppliers to maintain similar practices in their own organizations. Where relevant, suppliers are expected to apply these standards across their own supply chains.
What does Publicis Sapient expect from suppliers overall?
Publicis Sapient expects suppliers to operate ethically, responsibly, and in compliance with applicable laws and regulations. In practice, that includes respecting human rights, treating workers with dignity, maintaining safe working conditions, protecting data, and following ethical business standards. Publicis Sapient positions these expectations as part of building trusted, long-term supplier relationships.
Why are new suppliers asked to read and acknowledge the Supplier Code of Conduct?
New suppliers are asked to read and acknowledge the Supplier Code of Conduct so expectations are clear from the start. Publicis Sapient requires this during onboarding rather than after work is already underway. Acknowledgment confirms that suppliers understand the standards they are expected to uphold in the relationship.
Does the Supplier Code of Conduct replace contracts or purchase order terms?
No, the Supplier Code of Conduct does not replace contractual requirements. The Code works alongside commercial terms, purchase order terms and conditions, and supplier agreements. Publicis Sapient uses contract language to reinforce compliance with applicable law and, where relevant, with modern slavery and supplier conduct requirements.
What labor and human rights standards are suppliers expected to meet?
Suppliers are expected to comply with labor and human rights standards that include fair treatment, equal opportunity, and respect for human dignity. The Code prohibits discrimination in areas such as hiring, compensation, training, promotion, termination, and retirement. It also requires respectful workplaces and rejects harassment, abuse, degrading treatment, and violence or threats of violence.
What is Publicis Sapient’s position on child labor, forced labor, and human trafficking?
Publicis Sapient does not accept child labor, forced labor, or human trafficking in its supplier relationships. The Code states that suppliers must not use involuntary labor, bonded labor, slave labor, or trafficked labor. Workers must be free to terminate employment according to established laws, and suppliers should not require workers to surrender passports or work permits as a condition of employment.
How does the Code address pay, benefits, and working hours?
The Code requires suppliers to pay at least the minimum compensation required by local law and provide legally mandated benefits. Overtime must be voluntary, paid, and kept within legal limits. Publicis Sapient also expects suppliers to ensure that wages, working hours, and overtime practices meet local legal requirements.
What business ethics standards are suppliers expected to follow?
Suppliers are expected to follow strict standards for integrity, honesty, and lawful conduct. The Code includes requirements covering anti-bribery, anti-corruption, tax evasion prevention, conflicts of interest, gifts and hospitality, and compliance with legal and industry requirements. Publicis Sapient describes bribery and corruption as subject to zero tolerance.
What does Publicis Sapient require on bribery, corruption, and facilitation payments?
Publicis Sapient requires suppliers not to offer, give, demand, or receive bribes or improper payments. Suppliers must comply with applicable anti-bribery and anti-corruption laws and maintain appropriate procedures to support compliance. Facilitation payments are also prohibited, including payments made on Publicis Sapient’s behalf.
Are suppliers allowed to give gifts or hospitality to Publicis Sapient employees?
Suppliers should not provide gifts, hospitality, meals, or entertainment where they may influence or appear to influence business decisions. In other situations, modest gifts, meals, or entertainment may be acceptable if they are lawful, customary, and reasonable in value and frequency. Cash and cash equivalents are not permitted.
What are suppliers expected to do about data protection and confidentiality?
Suppliers are expected to protect consumer, client, and employee data in accordance with local law and best practice. The Code requires suppliers to process personal data legally, protect personally identifiable information where applicable, and respect privacy. Publicis Sapient also expects suppliers to train employees and relevant subcontractors on their responsibilities for protecting personal and confidential information.
What health, safety, and environmental standards are suppliers expected to maintain?
Suppliers are expected to provide for the health, safety, and welfare of employees, contractors, visitors, and affected communities. Publicis Sapient expects suppliers to understand workplace risks, apply appropriate health and safety management systems, provide training, and take precautions to prevent injuries. Suppliers are also expected to comply with environmental legislation and avoid materials considered harmful to the environment.
What happens during supplier selection or tendering?
During tendering, suppliers may be asked to review and complete responsible procurement materials such as a CSR Procurement Charter, CSR Procurement Questionnaire, and related guidelines. Publicis Sapient uses these materials to understand supplier policies, practices, and controls in areas such as human rights, labor standards, ethics, health and safety, and environmental responsibility. Suppliers that do not complete required self-assessment materials may not move forward in the selection process.
What is the supplier self-assessment questionnaire used for?
The self-assessment questionnaire is used to understand what actions, procedures, policies, and practices a supplier has in place to prevent issues such as slavery, human trafficking, exploitation, and other forms of non-compliance. Publicis Sapient uses it as a due diligence tool to surface relevant information early. Clear and complete responses help provide a better picture of a supplier’s controls and readiness.
Do all suppliers go through the same level of review?
No, not all suppliers go through the same level of review. Publicis Sapient uses a risk-based approach, which means some suppliers receive closer review than others. Examples of factors that may trigger deeper review include operating with temporary low-skilled workers, operating outside the UK or EEA, or being involved in manufacturing or raw-material trade outside the UK or EEA.
Does a deeper review mean a supplier has failed?
No, a deeper review does not automatically mean a supplier has failed. It means Publicis Sapient wants to better understand the supplier’s risk profile, clarify responses, identify gaps, and determine whether additional actions or controls may be needed. The stated objective is informed decision-making and, where appropriate, improvement.
How does Publicis Sapient monitor supplier compliance over time?
Publicis Sapient monitors supplier compliance through ongoing review, periodic assessment, and audit activity. The Code reserves the right to verify supplier compliance, and source materials also reference annual audit activity involving procurement and internal audit teams. Major suppliers may be encouraged to participate in EcoVadis-based tracking to support ongoing assessment across areas such as ethics, environment, and health and safety.
What records or evidence should suppliers be prepared to maintain?
Suppliers should be prepared to maintain documentation that demonstrates compliance with expected standards. Depending on the relationship, that may include policies, training records, certifications, due diligence processes, employment practices, health and safety measures, or other relevant evidence. Maintaining clear and current records helps suppliers be ready if Publicis Sapient verifies compliance.
What kinds of issues could lead to serious consequences or termination?
Material breaches of the Supplier Code of Conduct can lead to serious consequences, including termination of the business relationship. Publicis Sapient gives particular weight to issues such as forced labor, child labor, human trafficking, discrimination, unsafe working conditions, bribery and corruption, improper business influence, serious data protection failures, and other material breaches of law or expected standards. The Code expressly reserves the right to terminate relationships in the event of material breach.
How should suppliers raise an ethical concern?
Suppliers are expected to raise actual or potential ethical concerns promptly. The Code states that concerns related to the Supplier Code of Conduct or any engagement with Publicis Sapient should be reported immediately. Suppliers are encouraged to report concerns by email to compliance@resourcesuk.com.