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In recent months, the LLB Group has fundamentally revised its Code of Conduct to align with the evolving requirements and values of our Group. The Group regulations on “Conflict of Interest Management” and “Compliance Management” have also been updated.

By Cornelia Zeh

The Code of Conduct guides behaviour within the LLB Group – from our Group Board of Directors to the Group Executive Board and our employees. It forms the basis for two other important sets of rules: “Conflict of Interest Management” (previously “Rules of Conduct”) and “Compliance Management”. We spoke to Roger Dornier, General Counsel of our Group and Head of Group Legal & Regulatory, about these policies, the main changes, and their significance.

Roger, the Code of Conduct has been revised – why was this necessary?

The Code of Conduct is the foundation of our actions, guiding how we handle potential questions or challenging situations that impact our business practices or our interactions with each other. It is a crucial part of our corporate culture and our daily work. The Code was revised as part of the regular resubmission process, reflecting our updated values, new market presence, and evolving regulatory requirements.

A key focus in this Code of Conduct is how we handle potential conflicts of interest. Another important aspect is the consistent handling of rules and standards, ensuring compliance with laws, regulations, and other requirements.

You mention conflicts of interest. What precisely does this mean?

A conflict of interest arises when opposing interests clash, and pursuing one interest could jeopardise the other. For example, imagine one of our client advisors, Mr XY, is closely related to the CEO of a corporate client – let's say the CEO is his father. In this situation, Mr XY might be tempted to make decisions that benefit his father or his father's company, even if those decisions are not in the best interests of the bank or other clients.

This means, for example, that this client relationship must be reassigned or managed collectively. If a conflict of interest cannot be avoided – which can easily happen in Liechtenstein – we must actively manage it. The key to this lies in full transparency regarding potential conflicts. Only then can we assess them and take risk-mitigating measures.

What measures can be taken to identify and manage such potential conflicts of interest?

It is a regulatory requirement to maintain a register of conflicts of interest. In the revised Group regulation on Conflict of Interest Management, we are now introducing more extensive disclosure obligations for employees. In this context, all employees will receive a questionnaire in the next few days, asking for specific information on potential conflicts of interest. For example, we will be asking questions about personal relationships, secondary employment, and political offices, and request that these questions be answered truthfully and in full.

We understand that we are collecting very personal information. However, this will be treated with the utmost confidentiality – only a small circle of colleagues from Group Regulatory & Compliance will have access to it, and even then, we operate strictly on a need-to-know basis.

You also mentioned consistent handling of rules and standards. What do you mean by that?

In accordance with the Code of Conduct, the bank punishes breaches and misconduct consistently and proportionately. This is in the interest of our clients in particular. In this context, we distinguish between minor and serious breaches of the rules. Minor breaches are assessed by the relevant manager together with the responsible HR Business Partner. Serious breaches are referred to the Integrity Committee. This committee is chaired by me and includes Bernd Moosmann as Head of Group Human Resources, Jousry Abdel-Khalek as CISO of the Group, the relevant division head at our headquarters in Liechtenstein or the local CEO of the Group company, and the relevant local business area head or board of management. The case is assessed by this committee.

Let me come back to the three documents: the Code of Conduct, the Group regulation on Conflict of Interest Management, and the Group regulation on Compliance Management. How do these sets of rules interact with each other?

These three sets of rules should not be viewed in isolation but are interlinked to create a strong, ethical corporate culture. The Code of Conduct forms the foundation, outlining the principles by which we act. It sets the direction for our behaviour, how we treat each other, and how we respond to challenges.

Conflict of Interest Management builds on the Code of Conduct by specifically identifying situations where personal interests might conflict with the interests of the bank. The goal is to detect such conflicts early, make them transparent, and manage them effectively. Our aim is to minimise potential risks and ensure the integrity of our decisions.

Finally, Compliance Management ensures that all legal and regulatory requirements are adhered to. It provides the necessary monitoring and control, helping us to continuously review and improve our actions.

This integrated approach ensures that our values and standards are firmly anchored and consistently practiced in our daily activities.