LensCrafters 2013 Annual Report Download - page 70

28
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. 231/2001.
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;
• to provide information about the serious consequences which the Company may
suffer (and therefore also its employees, managers and top managers) from the
enforcement of pecuniary and prohibitory fines provided for in the Decree and the
possibility that such measures may be ordered as an interim measure; and
• to enable the Company to exercise constant control and careful supervision of its
activities, in order to be able to react promptly in the event that risks arise and
possibly enforce disciplinary measures provided for by the Model itself.
The Model is available on the website www.luxottica.com in the
Company/Governance/Model 231 section.
The Supervisory Board in office until the approval of the financial statements as of December
31, 2014 is composed of two external professionals, Mr. Giorgio Silva and Mr. Ugo Lecis,
and by the Internal Audit Manager, Mr. Alessandro Nespoli. The Board of Directors, at the
time of its appointment on April 27, 2012, considered it appropriate to maintain a
Supervisory Board made up of the Internal Audit Manager and two external, independent
professionals, instead of entrusting the Board of Auditors with the task, as permitted by
recent amendments introduced by Italian Legislative Decree 231/2001. This choice was
deemed appropriate for combining the requirements of independence and expertise, both of
which are fundamental for being able to guarantee authoritativeness and effectiveness to the
work carried out by the Supervisory Board.
The Board reports every six months to the Board of Directors, the Control and Risk
Committee and the Board of Statutory Auditors on the activities performed.