LensCrafters 2007 Annual Report Download - page 100

ANNUAL REPORT ON
CORPORATE GOVERNANCE 2007 | 99 <
Code of Ethics. Luxottica Group's Code of Ethics identifies the values underlying all of the Group's
business activities and is continuously reviewed and updated to take into account any necessary
amendments, particularly those relating to U.S. regulations.
The Code of Ethics currently in force, which applies throughout the Group, was approved by the
Board of Directors on March 4, 2004 and updated by the same Board on October 27, 2005 to take
account of the changes relating to the appointment of a Code Guarantor.
On March 27, 2006, the Code of Ethics was further modified with particular reference to the new
rules governing the appropriate use of company assets by Group employees and others covered
by the Code.
During 2007, training was carried out to promote greater awareness of the contents of the Code of
Ethics and of the procedures for handling complaints and notifications of insider trading. The
Company ensured that all offices had a copy of the Code that was translated into the local
language and made available to all employees.
The Code of Ethics is available on www.luxottica.com
The Code of Ethics Guarantor is Sergio Scotti Camuzzi, an independent consultant for Luxottica
Group. His authority and independence was deemed to make him the most suitable person for
ensuring transparent and impartial management of the process of evaluating notifications and
complaints of violations of any of the principles contained in the Code of Ethics. The Guarantor will,
at least every six months, provide the Board of Statutory Auditors, the Internal Control Committee
and the Supervisory Body with information and an update on any complaints received and their
status.
Procedure for Handling Reports and Complaints Concerning Violations of Principles and Rules
Defined and/or Acknowledged by the Luxottica Group. On October 27, 2005, the Board of
Directors, after receiving approval from the Internal Control Committee, approved a “Procedure for
Handling Reports and Complaints Concerning Violations of Principles and Rules Defined and/or
Acknowledged by the Luxottica Group”.
This procedure covers complaints, claims and reports concerning cases of alleged fraud, violation
of the ethical and behavioral principles set forth in the Group's Code of Ethics and irregularities or
negligence in accounting, internal control procedures and auditing.
Complaints from both employees and others outside the Group are to be taken into consideration.
The Group undertakes to protect the anonymity of the informant and to ensure that no form of
retaliation will be taken against any employee who reports a violation.
This procedure applies to all Group companies.
Since 2007, a system has been introduced whereby the U.S. and Australian companies, which due
to their size and operations have introduced direct local procedures for dealing with reports of
possible violations of the Code of Ethics, report to the Guarantor every three months. Such
reporting, implemented with the help of the Guarantor, identifies in detail the types of reports of
violations which can be dealt with locally (with the Guarantor to be informed about them later) and
those which, because of their serious nature, must be brought directly before the Guarantor of the
Code of Ethics for evaluation and advice.
Code of Conduct. In March 2006, the Corporate Governance Committee for listed companies
promoted by Borsa Italiana issued a new version of the Code of Conduct, replacing the one drawn