Risk and compliance
Anticorruption Compliance Program
Luxottica is an international organization that operates in various institutional, economic, political, social and cultural settings which are continuously and rapidly evolving. Luxottica's global presence leads to great challenges and responsibilities including its ability to abide by all applicable laws, regulations and social responsibilities in the many jurisdictions in which it operates. Regulatory and social environments around the world are becoming more and more focused on specific anti-corruption legislations.
This evolution is aimed at strengthening the fight against corruption, a phenomenon that could lead to both ethical and business damages. From an ethical point of view, corruption harms the integrity of all those involved and undermines the basics of the organizations to which they belong. From a business point of view, corruption leads to sub-optimal outcomes for companies, legal risks, reputation disruption and financial costs, including fines.
With all this in mind, Luxottica initiated a Group "Anti-Corruption Compliance Program" named "Be transparent and keep it transparent", which applies globally and provides specific rules for preventing, detecting and managing corruption risks within the Group's sphere of influence. This program complements the programs already in place including the Company's Code of Ethics.
Directors, members of any committee of the Group's companies, employees, and business partners (including vendors and customers) are required to be aware of corruption risk and social responsibilities, and to operate strictly in compliance with applicable laws and regulations.
In our way to do business "Be transparent and keep it transparent" is not just a phrase: it is a way of thinking and acting that we must affirm. By doing so, each of us can do our part to protect Luxottica's ethical and responsible business conduct day after day.
Transparency in supply chain disclosure
Luxottica has adopted both a Code of Conduct and a Code of Ethics, with which employees, business partners and suppliers are expected to comply. Luxottica produces the vast majority of its products at facilities that it owns and where it controls hiring and employment practices. The Codes require that all associated with Luxottica behave ethically and within the bounds of the law, respect the rights of people’s dignity, health and safety, and that denounce the use of child labor. Luxottica promotes the safeguarding of workers’ rights, trade union freedom and freedom of association in general.
Luxottica investigates the reputation and lawfulness of the suppliers it uses, and supervises the observance by its suppliers of its Code of Ethics through frequent company employee visits. The company is in the process of deploying a Global Audit program designed to cover Environmental, Health, Safety & Social aspects.
Luxottica requires suppliers to comply with the laws of the jurisdiction in which the product is made and strives to ensure that the rights contemplated by the Universal Declaration of Human Rights are guaranteed in the different countries in which it operates.
Luxottica supervises the observance of the Code of Ethics, providing information, prevention tools and controls and assuring the transparency of its operations and behaviors, intervening with remedial actions as necessary. Compliance with the Code of Ethics is a requirement for continued employment or business relationship with Luxottica.
Regular training is a part of employment with Luxottica, including that related to compliance with the law. Specific training relating to human trafficking and slavery and mitigation of the risk of such practices with the supply chain is in the process of development.
Selection of suppliers and formulation of conditions of purchase of goods and services in Luxottica Group companies are based on principles of fair competition, objectivity, rectitude, impartiality, price equity and quality of goods and services, and takes into account guarantees of assistance and the scenario of offerings in general.
Procurement processes must be geared to obtaining maximum competitive advantage for Luxottica Group and loyalty and impartiality towards all suppliers in possession of the relevant requisites. Suppliers’ collaboration is continually sought to satisfy the needs of Luxottica Group’s clients in terms of quality and delivery times.
Stipulation of a contract with a supplier must always be based on the utmost clarity. All contractual constraints involving forms of dependence on a supplier must be avoided where possible.
The need to obtain maximum competitive advantage for Luxottica Group must in no way compromise the capacity of Luxottica Group or its suppliers to operate in line with current law and, more generally, with the commitment to safeguarding employees’ dignity, health and safety and to protecting the environment.
Conflict minerals sourcing
As an international organization that interacts with employees, customers, suppliers and business partners in 150 different countries around the world, Luxottica places great importance on protecting the people and environments in the areas where we operate. This includes ensuring that the materials we use to manufacture our products are sourced in a safe and ethical way.
In 2012, the Securities and Exchange Commission, driven by the Dodd-Frank Wall Street Reform and Consumer Protection Act, adopted rules requiring public companies to report the use of “conflict minerals” in their products. Conflict minerals include metals such as tantalum, tin, tungsten and gold which are mined in the Democratic Republic of Congo or a neighboring country. Profits from mining operations in these regions often become a source of financing for rebel groups associated with human rights violations.
As a result, in 2013, Luxottica adopted a “Responsible Sourcing” methodology and policies to ensure the responsible procurement of all minerals used to make our products. We require our suppliers to conduct the necessary due diligence in their supply chain, including proper source verification, to ensure their materials come from socially responsible suppliers. We have also taken the extra steps necessary to identify risks in the supply chain by implementing a risk reporting system, conducting ongoing site visits with key vendors and utilizing the tools of third party “conflict-free” experts including the Electronic Industry Citizenship Coalition and the Global e-Sustainability Initiative.
Modern Slavery Act 2015
Modern slavery is a crime and a gross violation of fundamental human rights. Luxottica is committed to making continuous improvements to workers’ employment and workplace conditions including, but not limited to, the prevention of forced, bonded and trafficked labour. This is supported by the company’s policies and initiative and is endorsed by a committed organisation and leadership.
This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps Luxottica has taken to ensure that slavery and human trafficking is not taking place in our supply chain or in any part of our business. It constitutes our slavery and human trafficking statement for the financial year ending 2018.
UK tax strategy
In compliance with section 161 and section 19(2) of schedule 19 Finance Act 2016, Luxottica Group is publishing its UK tax strategy.