LensCrafters 2011 Annual Report Download - page 165

| 89 >REPORT ON CORPORATE GOVERNANCE AND OWNERSHIP STRUCTURE
transactions that do not reach a total equivalent value of a further Euro 5,000 by the end of
the year do not need to be reported.
The procedure provides for black-out periods during which the interested parties are not
allowed to trade any Luxottica securities.
The procedure is available on the website www.luxottica.com, in the Governance/
Procedures section.
Procedure for the Processing of Confidential Information
On March 27, 2006, in compliance with articles 114, 115-bis of the Italian Consolidated
Financial Law and of articles 152-bis et seq. of the Regulations for Issuers, as well as
the regulations contained in the Code of Conduct, the Board of Directors adopted a
Procedure for the processing of confidential information (pursuant to article 181 of the
Italian Consolidated Financial Law), in order to ensure that the disclosure thereof is timely,
thorough and adequate. This procedure was last updated on February 14, 2012.
The following persons are required, among other things, to comply with the confidentiality
of such documents and information: (i) directors; (ii) statutory auditors; (iii) any manager in
Luxottica and in the companies belonging to the Group; and (iv) any other employees of
Luxottica and of the companies belonging to the Group who, by virtue of their function or
position, become aware of information and/or acquire information classified as confidential
information.
The procedure for the processing of confidential information also requires the identification
of the persons responsible for external relations, their expected behavior, the operational
procedures and related obligations to comply with the same. The policy also indicates the
characteristics, contents and procedures for updating the Register of people with access
to confidential information.
This Register was implemented by Luxottica in order to comply with the provisions of
article 115-bis of the Italian Consolidated Financial Law.
This policy is available on the website www.luxottica.com, in the Governance/Procedures
section.
Appointment of External Auditors
U.S. regulations in force provide that either the Audit Committee or the equivalent body
under the specific rules of the issuer’s home country must approve the services provided
by external auditors to the Company and to its subsidiaries.
To this end, on October 27, 2005, the Board of Directors approved the “Group Procedure
for the Appointment of External Auditors”, in order to protect the independence of the
external auditor, which is the fundamental guarantee of the reliability of the accounting
information regarding the appointing companies. This policy was last updated on October
25, 2010, also in order to adapt to Italian Legislative Decree 39/2010.