LensCrafters 2011 Annual Report Download - page 154

ANNUAL REPORT 2011> 78 |
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, 2008 and 2010, was updated by the resolution of the Board of Directors on July 25,
2011 in order to acknowledge several procedural and/or organizational changes within
the Group’s subsidiaries, and subsequently on February 14, 2012 in order to also include
crimes related to environmental protection.
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.
The purpose of the Model is the establishment of a structured and organized system of
procedures and control activities carried out mainly for prevention, such that the system
cannot be overridden unless by fraudulently failing to comply with its provisions.
To this end, the Model serves the following purposes:
• to make all those working in the name of and on behalf of Luxottica aware of the
need to accurately comply with the Model, and that the violation thereof shall result in
severe disciplinary measures;
• to support the condemnation by the Company of any behavior which, due to
a misunderstanding of corporate interest, is in conflict with the law, rules or more
generally with the principles of fairness and transparency upon which the activity of
the Company is based;