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In addition to the Code, there is a Procedure for the Handling of Reports and Complaints of Violations of principles and
rules defined and/or acknowledged by Luxottica Group.
The procedure covers reports, complaints and notifications of alleged fraud, violation of ethical and behavioural principles
set forth in the Code of Ethics of the Group and of irregularities or negligence in accounting, internal controls and
auditing.
Complaints received from both internal and external subjects by the Group are taken into consideration: the Group
undertakes to safeguard the anonymity of the informant and to ensure that the employee reporting the violation is not
subject to any form of retaliation.
The reports of violations of principles and rules defined or recognized by the Group are submitted to the person in charge
of the Internal Audit, who in turn submits them to the Chairman of the Board of Statutory Auditors.
The Code of Ethics is available on www.luxottica.com, in the Company/Values and Ethics section.
Procedure for transactions with related parties
On October 25, 2010, the Board of Directors voted unanimously to adopt a new procedure to regulate transactions with
related parties pursuant to the new provisions of CONSOB regulation 17221/210.
The procedure, which was approved by the Internal Control Committee (composed exclusively of independent Directors),
became applicable beginning January 1, 2011.
The procedure regulates the execution of major and minor transactions. Transactions with and among subsidiary
companies, associated companies, ordinary transactions, transactions of an inferior amount (of an amount less than Euro
2.5 million or, with regard to the remuneration of a member of a management or control body or managers with strategic
responsibilities, of an amount less than Euro 250,000) are excluded from the application of the procedure.
The Board of Directors also resolved, as authorized based, among other things, on the interested parties involved in each
individual transaction, that: (i) the Human Resources Committee – composed of non–executive directors, the majority
being independent – were involved and consulted regarding transactions for the remuneration and economic benefits of
the members of the management and control bodies and managers in strategic roles; (ii) the Internal Control Committee
was involved and consulted regarding other transactions with related parties.
Further information on the application of the procedure with regard to remuneration and assignment of benefits to the
members of the management and control bodies and managers in strategic roles are stated in the previous paragraph
“Remuneration of Directors”.
The “Guidelines for Transactions with Related Parties” were applied until December 31, 2010.
Both documents are available on the website www.luxottica.com, in the Governance/Procedures section.
Internal Dealing Procedure
On March 27, 2006, in order to implement internal dealing regulatory changes, as set forth in Art. 114, seventh paragraph,
of the Italian Consolidated Financial Law and Art. 152–sexies et seq. of the Regulations for Issuers, the Board of Directors
approved the Internal Dealing Procedure. This Procedure was last updated on March 13, 2008.
The Internal Dealing Procedure regulates in detail the behavioral and disclosure obligations relating to transactions in
Luxottica shares or American Depositary Receipts (ADRs) completed by so–called “relevant parties”.