Publicis Limited

Modern Slavery Statement

Introduction

This statement outlines the actions taken by Publicis Limited (the “Company”) to prevent slavery and human trafficking within its business and supply chain. The Company is committed to improving its practices to combat slavery and human trafficking. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) and constitutes the Company’s slavery and human trafficking statement for the financial year 1 January 2017 to 31 December 2017.

Organisational Structure and Business

The Company operates as a creative agency, helping to build future-fit brands and providing strategic, creative, and digital ideas to help clients Lead the Change and succeed in their marketing transformation. The Company’s ultimate parent is Publicis Groupe S.A, a French incorporated listed entity (the “Groupe”).

Our Supply Chains

The Company’s supply chains include IT and other office equipment, professional services, office cleaning, and other office facilities services. The Company and the majority of its suppliers are based in the UK, and the supply chain is considered low risk and non-complex in structure.

Our Policies on Slavery and Human Trafficking

Our stance on slavery and human trafficking is clear. We have long-established policies, processes, and practices in place to prevent these issues within our business operations and supply chains. We continuously seek ways to enhance these processes and currently undertake the following measures:

• It is now our policy to require all suppliers to adhere to our Suppliers Code of Conduct (the “Code”). Among other governance and compliance obligations referenced in the Act, the Code sets out the minimum behaviours, standards, and practices we expect from our suppliers. It prohibits forced labour, discrimination, and child labour, ensures supplier working conditions are safe, and that workers are treated with respect and dignity, with the aim of preventing slavery and human trafficking in our supply chains or business operations. The Code is published on our external website, and all new suppliers are required to read and acknowledge it as part of the onboarding process.
• Our Purchase Order Terms and Conditions and Global Supplier Agreements require all suppliers and vendors to comply with all applicable laws and have recently been updated to include compliance with the Act.
• We practice responsible procurement. Contracts signed with major suppliers, whether central or regional, are encouraged to mobilize in favour of human rights through our internal 'CSR Procurement Charter' and 'CSR Procurement Questionnaire,' which are sent to all suppliers during the tendering process. Suppliers also receive CSR Procurement guidelines, and their actions and commitment to CSR are tracked through our internal platform, EcoVadis. Only suppliers who have completed the self-assessment may progress to the next step, which is the selection process. Major suppliers are encouraged to join the EcoVadis platform, which audits suppliers’ corporate social responsibility standards, including health and safety, environment, and ethics, so we can measure and monitor their progress and compliance with our policies.
• We fully comply with all UK employment laws and have internal HR policies in place to prevent slavery and human trafficking. These are included in the employee handbook, which is circulated to all employees and covers recruitment, health & safety, harassment, anti-bribery, equal opportunities, and diversity. Employees have access to a confidential whistleblowing process for raising concerns, and we continue to increase awareness among employees through training on issues relating to slavery and human trafficking so that they may report any concerns as they arise. Since the Act came into force, we have drafted a Modern Slavery policy, which has been circulated to all employees and is communicated to all new joiners during the induction process.
• The Groupe has been a signatory of the Global Compact 10 Principles of the United Nations since 2003, which includes protecting universal human rights and the elimination of all forms of forced and compulsory labour and child labour. The Groupe is committed to ensuring these principles are observed, as highlighted in its code of conduct and a defined set of internal policies, procedures, and processes (known as JANUS). JANUS sets out the compliance and governance processes applicable to all global subsidiaries, including the Company, to help prevent slavery and human trafficking and promote human rights. JANUS is distributed to all employees and is also available on the intranet.

Risk Assessment and Due Diligence

With the introduction of the Act, we assessed our supply chain for potential areas of increased risk of slavery and human trafficking. As part of our initiative to identify and mitigate these risks, we conducted a review of all our major suppliers and identified those in high-risk areas.

We ask all existing and new suppliers to complete a self-assessment questionnaire detailing any actions, procedures, policies, and practices their organisation undertakes to prevent slavery and human trafficking. All suppliers must agree to adhere to the Code, a copy of which is attached to the questionnaire, and are required to annually certify a declaration form confirming understanding and compliance with the Code and the Act.

High-risk suppliers receive a more detailed review of their questionnaires to identify areas of concern that may conflict with our Code or the Act, better understand the risk, provide feedback, and agree on steps to improve their processes. High-risk suppliers that receive special attention include companies that operate using temporary low-skilled workers, operate outside the UK or EEA, and/or manufacture or trade in raw materials outside the UK or EEA.

We continually assess our compliance with the Act through annual internal audits carried out by our procurement, internal audit, and HR teams.

Further Steps

We will periodically review the effectiveness of our processes and systems, and any changes will be reflected in future annual statements.

This statement has been approved by the board of directors of the Company.

Signed
For and on behalf of
Publicis Limited
Nicholas Farnhill
Director
Date: 27/02/2019

• Publicis Limited Modern Slavery Statement 2017
• Modern Slavery Risks and Mitigation in Digital Transformation: Sector-Specific Insights
• Lutte contre l’esclavage moderne et respect des droits humains dans la transformation digitale en Europe (Europe)
• A Deep Dive into Publicis Sapient’s Supplier Code of Conduct: Ensuring Ethical Partnerships in Digital Transformation
• Negocios Responsables en América Latina: Modernidad, Derechos Humanos y Ética en la Cadena de Suministro Digital (LATAM)
• Lutte contre l’esclavage moderne et respect des droits humains dans la transformation digitale en Europe (Europe)
• Negocios Responsables en América Latina: Modernidad, Derechos Humanos y Ética en la Cadena de Suministro Digital (LATAM)
• Modern Slavery in Digital Transformation: Sector-Specific Risks and Best Practices
• Negocios Responsables en América Latina: Liderando la Transformación Digital con Ética y Respeto a los Derechos Humanos (LATAM)
• A Deep Dive into Publicis Sapient’s Supplier Code of Conduct: Ensuring Ethical Partnerships in Digital Transformation