LensCrafters 2010 Annual Report Download - page 98

ANNUAL REPORT 2010> 96 |
The Committee has access to the information and the Company functions necessary for the performance of its task as
well as to work with external consultants. The Board of Directors approved the allocation of funds totalling Euro 50,000
to the Committee for the 2011 fiscal year in order to provide it with the adequate financial resources to perform its tasks
independently. A similar decision had been taken for the 2010 fiscal year.
The Internal Control Officer
The Internal Control Officer is responsible for ensuring the adequacy and efficiency of the internal control system and
proposing corrective measures, provided he/she is given adequate means to perform his/her duties and has direct access
to any information useful for the performance of these duties.
The Internal Control Officer has been identified by the Board of Directors, upon the proposal of the Chief Executive Officer,
as the manager of Internal Auditing of Luxottica Group, Mr. Luca Fadda. The guidelines concerning his remuneration have
been approved with the favorable opinion of the Internal Control Committee.
The Internal Control Officer reports to the Chairman and to the Chief Executive Officer – the executive manager supervising
the functionality of the internal control system – and reports on the performance of his duties to the Chief Executive Officer,
as well as to the Internal Control Committee and to the Board of Statutory Auditors, in its function as Audit Committee.
The Internal Control Officer is not responsible for any operational area and has access to any information useful for the
performance of his duties. He is provided with a budget, determined by the Company, which is allocated consistently with
the activities performed to reach the objectives set in the plan approved by the competent bodies.
In the course of the fiscal year, the Internal Control Officer has performed his role through the implementation of an activities
and verifications plan, related to the Company and its main subsidiaries. Such actions, which the Officer periodically has
reported to the Chairman, the Chief Executive Officer and the Board, through the Internal Control Committee and the
Board of Statutory Auditors, have allowed the Company to identify areas for improvement of the internal control system,
for which specific plans have been implemented to further strengthen the foundations of the system itself.
Organization, Management and Control System pursuant to Italian Legislative Decree no. 231/2001
On October 27, 2005, the Board of Directors implemented the Organization, Management and Control System, as
established by Italian Legislative Decree no. 231/2001 in order to prevent the risk of employees and consultants of the
Company carrying out illegal acts, with the consequent administrative liability as provided for by Italian Legislative Decree
no. 231/2001 (hereinafter the “Model”).
The Model, which was subsequently modified in 2006 and 2008, was most recently updated by the resolution of the
Board of Directors on July 26, 2010 in order to include the new illegal acts introduced by the recent provisions of law,
such as: falseness of identification tools or marks, crimes against industry and trade and crimes related to the violation of
copyright.
Particular importance is given to the “point persons” of the Supervisory Board (the Operational Unit Supervisors), or to the
persons that perform functions considered to be the most “sensitive” activities pursuant to Italian Legislative Decree 231,
who constantly monitor the implementation of the Model, within their area of responsibility, and report to the Supervisory
Board every six months.
Following the update of the Model, and in continuation of the training programs from the past few years, training initiatives
have been established for areas which are considered “sensitive” pursuant to Italian Legislative Decree no. 231.