Information unaudited Information ungeprüftDiversity and equal opportunities

For years now, the LLB Group has been committed to diversity and equal opportunities for its employees. We support teams that are characterised by diversity. Our mission is to offer all employees the same opportunities in terms of employment, salaries and career progression.

There is evidence that diverse teams are better able to question processes and thought patterns, as well as develop and come up with innovative ideas. A broad-based workforce where everyone is afforded the same opportunities ensures the LLB Group has a talent pool in which different experiences and expertise complement each other. This is why we offer all employees the same opportunities in terms of employment and promotion, regardless of gender, age, religion, nationality, ethnic background, sexual orientation, marital or family status and physical ability levels.

General information

As a universal bank, the LLB Group offers a wide variety of jobs and covers a broad range of subject areas. To acquire and retain talent, it relies on a humane corporate culture that is characterised by partnership-based cooperation. The targeted development of employees and a modern compensation system also act as motivators. There are various channels of communication for them to express their opinion and their needs. In line with the countryʼs investment strategy, we consider the ethical and social responsibility towards employees when implementing our corporate strategy.

Material impacts, risks and opportunities

As part of the double materiality assessment, the following material impacts, risks and opportunities (IROs) have been identified in relation to our own workforce:

• We make positive impacts by actively promoting diversity and equal opportunities within our workforce. Employees feel valued and respected through targeted measures. We place particular focus on women and people over 50 years of age. As the measures are implemented at all locations, we are expecting a positive effect over the medium term.
• Another positive impact is the improvement in work / life balance for our staff. We promote this by offering flexible working models such as part-time roles, job sharing and working from home. The measures referred to are particularly beneficial to staff with family commitments – regardless of their age, gender or level of seniority. They are available to permanent employees at all locations. Here too, we believe the likelihood of positive medium-term impacts is high.
• We at the LLB Group are actively committed to equal pay, which has positive impacts on our employees. Through targeted measures to review and adjust salary structures, we ensure all employees receive fair and equal pay, regardless of gender or age. These initiatives promote a fair and inclusive working environment, strengthen employee motivation and help with long-term retention of talented professionals.
• However, negative impacts on women in our workforce are still possible on account of the business context in which we operate. Women are still underrepresented in the banking sector. This makes it harder to appoint qualified female employees, and there is a danger that the under-representation will continue in the short to medium term. We at the LLB Group are working hard to counteract any negative impacts on gender equality. Given the measures already implemented, we believe the likelihood of these occurring is low over the medium term.
• The LLB Group is running a risk, unless it adopts a systematic approach to tackling violence, discrimination and harassment in the workplace. Individual incidents of this kind create an unsafe working environment, which may have a negative impact on employee motivation and satisfaction, increase staff turnover and damage the businessʼs image. Currently, there are no negative financial effects on account of this risk.
• There is also a risk of biased or one-sided decisions if we fail to take sufficient account of the perspective of women within the LLB Group. Currently, there are no negative financial effects on account of this risk.
• Offering a range of internal and external training courses for all employees represents a big opportunity for us, because it allows us to both develop their skills and enhance our position as an attractive employer. It also helps us pave the way for innovative thinking and new solutions.

Impacts on the workforce

Women are particularly affected by the impacts identified, although we have not noticed any significant differences between geographical locations. This assessment is based on an evaluation of the key HR figures and results of the employee survey, which fed into the materiality assessment. We have also involved the Representation of Employees (Liechtenstein) and the works council (Austria) in the double materiality assessment, which has given us a better understanding of employee categories at particular risk.

With ongoing input from our employees, we are trying our best to ensure our business activity has no material negative impacts on the workforce. We have not come up with a firm estimate of the human or financial resources required for the management of such impacts. Any costs arising are generally covered by the HR budget.

Relationship with strategy and business model

The negative impacts on our employees, as identified in the double materiality assessment, are not directly related to the strategy or the business model of the LLB Group. Our corporate strategy and internal rules and regulations, the way the business is aligned, the human resources policy and the kinds of activities we pursue do not favour any group of employees, so have no negative impact on gender equality. We are also responding, with our diversity strategy, to any potential negative impacts the LLB Group may have on gender equality.

As described in the Economic role and regional employer section, we are reliant, as a provider of services, on motivated and qualified employees. In order to remain attractive to potential candidates, we place an emphasis on having an appealing and modern working environment. Numerous measures in recent years have been aimed at recruiting potential applicants and retaining existing employees. In doing so, we not only ensure the quality of our services, but also guarantee that the LLB Group remains competitive and we achieve positive effects for our employees.

Involvement of employees

We have various channels for identifying material impacts, risks and opportunities. The feedback we receive via these channels feeds into our materiality assessment (see the Double materiality assessment section). At the same time, employees are provided with targeted information, on an ongoing basis, about new developments in the area of sustainability. Responsibility for this is shared between Group Corporate Communications & Sustainability and the heads of the sustainability streams.

We are constantly monitoring the needs and interests of our employees and take these into account in our business decisions. One relevant tool for this purpose is the employee survey. Impacts on the sustainability aspects of diversity and equal opportunities are monitored on an ongoing basis, partly with the help of the HR or Diversity & Inclusion Cockpit, which provides the main key figures in this area. The diversity strategy picks up on the main content. Decision makers within the business are also in constant contact with the Representation of Employees (Liechtenstein) or the works council (Austria). With the whistleblowing tool and the Integrity Committee, employees have further channels for communicating their concerns and needs.

The interests, standpoints and rights of our employees are taken into account in both the Investment Strategy of the Principality of Liechtenstein and our corporate strategy ACT-26. The investment strategy sets out the specific requirement, when defining and implementing the corporate strategy, to take account of the ethical and social responsibility towards employees. This includes gender equality, promoting the health and physical and mental well-being of employees as well as continuous advancement through training and professional education (see the Economic role and regional employer section). ACT-26 includes the commitment to be a family-friendly and exemplary employer. Our diversity strategy also focuses on gender equality and a healthy generational mix.

In terms of the interests, standpoints and rights of our employees, we have not made any amendments to our business model. We have not come up with a firm estimate of the human or financial resources required for measures to promote employee involvement.

Employee surveys

We conduct regular in-depth employee surveys at the companies of the LLB Group. Their results feed into business decisions. The last survey was conducted in 2023. All permanent and temporary LLB Group employees were entitled to take part. The response rate of 91 per cent was very high, and we improved in three out of four target values compared with the previous survey: “Attractive employer”, “No resignation” and “Satisfaction” (see the Our role as a regional employer section). As a general rule, Group Human Resources conducts an employee survey of this kind every three years with an external institution. We pick up on the results in employee workshops, which are also attended by individual members of the Group Executive Board. In the past, such workshops have been held in Liechtenstein, Austria and Switzerland; the United Arab Emirates was excluded.¹ The Group Executive Board decides on follow-up measures.

Representation of Employees

The Arbeitnehmervertretung (Representation of Employees – ANV) at LLB in Liechtenstein serves as the mouthpiece for the workforce and helps ensure strategic decisions take direct account of employeesʼ interests. It is in regular contact with the Group Executive Board and has a say in various issues such as staff pension plans, rationalisation projects and staff retrenchment. It also represents the viewpoint of the workforce in working groups like the Mobility Commission and the Working Atmosphere and Health Commission. The Group Executive Board is obliged to inform the ANV regarding all matters that are relevant to employees. The Group CEO and the Head of Group Human Resources carry out this task on a quarterly basis.

Our organisational rules provide information on the rights and obligations of the ANV and can be accessed by all employees via the intranet. They can approach the ANV with their concerns both anonymously and confidentially. If employees so wish, it will not reveal their identity to the Group Executive Board.

LLB Österreich has its own arrangement for the representation of employees in the form of the works council; there is no such committee in Switzerland or Germany.

Whistleblowing tool and Integrity Committee

Our employees can use a number of complaints procedures and reporting channels to express their concerns and raise any grievances. Our whistleblowing tool allows them to file complaints anonymously or point out improper conduct. We conduct training courses on the whistleblowing tool and have set up our own Intranet page where we provide information on the tool. In the year under review, two reports were received via the whistleblowing tool. Neither report resulted in fines, sanctions or compensation payments.

All employees can discuss their concerns with members of the Integrity Committee at any time. The Corporate governance and integrity section has more information on the composition and role of the Integrity Committee as well as on the whistleblowing tool.

1Germany is not taken into account as the LLB Group only expanded into this market in 2024.

Grievance mechanisms and remedial measures

In addition to the open corporate culture, our employees also have various channels for raising any issues and concerns. These include the opportunity to ask questions via the Group Forum, the employee survey, the Representation of Employees / works council and our whistleblowing tool (see the Involvement of employees section). Employees may also take their issues and concerns to the relevant HR Business Partner, manager or the MOVIS counselling service. MOVIS is an external social counselling service, with which the LLB Group has a partnership. It is therefore an integral part of our corporate health management policy. We have dedicated a separate intranet page to the counselling service and what it offers. An anonymised reporting mechanism provides information on the use of MOVIS by LLB employees.

Reports from employees are dealt with consistently, and promptly if possible. In cases involving serious allegations (discrimination, violence, bullying), those responsible at Group Human Resources will discuss the matter with the persons concerned and work together with them to find solutions. Top priority is given to safeguarding the privacy of those concerned and securing their consent. Disciplinary measures may be taken in the event of serious violations. Employees who use the grievance mechanisms referred to are covered, where required, by the whistleblower protection provisions set out in greater detail in the Corporate governance and integrity section.

Strategies for dealing with human rights

The LLB Group is a participant in the UN Global Compact. This represents an undertaking to ensure that our business activity takes account of basic employment and human rights, environmental protection and the fight against corruption. We have therefore consistently implemented the respective requirements, under national and European law, on the protection of employee and human rights. Our own Code of Conduct and our Supplier Code of Conduct also include a clear commitment to promoting and supporting human rights. For example, we have set up a Representation of Employees or a works council in Liechtenstein and Austria. The members of these two bodies are chosen via free and independent elections and offer employees their services and support during working hours.

In addition to statutory minimum rights, we also offer employees the following benefits: special leave for caring responsibilities, right to purchase additional days of leave, scope for reducing / increasing working hours, insurance for non-workplace accidents, subsidised catering, training / educational opportunities, career planning and lots more.

In the event of any actual or suspected human rights violations, various grievance mechanisms are available to our employees (see the Grievance mechanisms and remedial measures section).

As regards the rights of our workforce, we take our lead from the UN Guiding Principles on Business and Human Rights, the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work and guidelines from the Organisation for Economic Co-operation and Development (OECD) for multinational companies.

For the most part, the countries where the LLB Group has a presence are not associated with any significant risk of forced or child labour. According to the Global Slavery Index 2023, our target markets of Switzerland, Austria and Germany are among the countries with the lowest rates of modern slavery and forced labour worldwide. No comparable data is available for Liechtenstein, although we believe the situation to be similarly stable. We also have two representative offices in the United Arab Emirates (UAE), which is regarded as a country with a high risk of forced and child labour.² By having European staff in management roles, both locally and at the head office in Vaduz, who are involved in the recruitment of new employees and procurement, we guarantee the provisions of our Code of Conduct and our Supplier Code of Conduct are complied with in the UAE too. Both documents make it explicitly clear that forced and child labour have no place at the LLB Group.

2According to the Global Slavery Index 2023, the UAE has one of the worldʼs highest rates of modern slavery. Children are affected too. See: https://www.walkfree.org/global-slavery-index/country-studies/united-arab-emirates/ (accessed on 3 February 2025).

We do not have any separate guidelines on the prevention of workplace accidents as the bankʼs activities carry a low risk of accidents. We do, however, ensure that all statutory provisions on workplace safety are complied with.

General characteristics of LLB Group employees

We collate key figures for employees as at 31 December of the respective year. Both the headcount and the full-time equivalent (FTE) figure are disclosed. As apprentices and those on the Young Talents programme are only in training, they are recorded at 50 per cent of their actual activity level at all banks in Liechtenstein. The FTE is calculated in relation to the agreed maximum working hours at the respective legal entity.

Employees by gender

As at 31 December 2024, 1ʼ501 people are employed Group-wide, a 5.5 per cent increase on the previous year. The increase is partly due to our growth initiative in Germany and Switzerland and to additional posts created at the head office in Liechtenstein. The number of employees in Austria remained largely unchanged.

Employees by location

Employees by employment type and gender

A significant rise in the figure for full-time equivalents was recorded as at 31 December 2024. 1ʼ286 people represents an increase of over 6 per cent on the previous year. The number of full-time employees showed a bigger increase than the number of part-time employees.

Employees by employment type and region

In the reporting year, a total of 113 employees left the LLB Group (2023: 135). The turnover rate of 8.5 per cent is significantly less than for the previous year (2023: 10.9 %).

There are no non-employees, as per the European Sustainability Reporting Standards (ESRS), working at the LLB Group.

Diversity of the workforce

We promote diverse and performance-oriented teams that deliver outstanding results. We place particular emphasis on gender equality and a healthy generational mix.

Strategy

The “Beteiligungsstrategie der Regierung des Fürstentums Liechtenstein für die Beteiligung an der Liechtensteinischen Landesbank AG” (Participation Strategy of the Government of the Principality of Liechtenstein for the Participation in Liechtensteinische Landesbank AG) sets out clear expectations of the LLB Group. According to this, its bodies must also take account of the ethical and social responsibility towards employees, such as ensuring gender equality, when implementing the corporate strategy (see the Our role as a regional employer section).

We take account of these requirements in our diversity strategy. It defines the general objectives, measures and key figures relating to the diversity of our employees. Our vision could also be expressed as follows:

• We are an attractive employer for all generations.
• We have an appropriate gender balance at all levels.

We have chosen gender and generational mixes as specific core issues:

• We want to see ongoing increases in the proportion of women and younger employees in leadership positions.
• With a view to achieving a generational mix, we want to retain deserving employees for longer and help younger employees with potential to progress more quickly.

The diversity strategy applies across the Group to all permanent and temporary LLB Group employees. The Group Human Resources business area, which reports directly to the Group CEO, is responsible for implementation. A dedicated HR or Diversity & Inclusion Cockpit has been created for ongoing monitoring of progress. This contains all the relevant key figures (such as turnover and absence rates). The Cockpit also provides the basis for any changes that need to be made to the chosen measures.

Policies

In addition to the diversity strategy, the Group regulation “Fit & Proper – Eignungsprüfung von Mitgliedern der Geschäftsleitung, des Gruppenverwaltungsrates und von Inhabern von Schlüsselfunktionen” (Group regulation on “Fit & proper – assessment of the members of the Board of Management, the Group Board of Directors and the holders of key functions”) is of particular relevance to the “Diversity of the workforce” sustainability aspect. This sets out the process for looking for, selecting, assessing and onboarding members of the Board of Directors and the Board of Management and employees in defined key functions. The aim is to take due account of specific statutory requirements relating to candidatesʼ technical and personal competencies. The Group regulation also goes into greater detail regarding the issue of diversity and equal opportunities. It rejects any form of discrimination and is consistently observed and implemented when the positions referred to are filled. Responsibility lies with Group Legal & Regulatory.

Measures

We do not have a separate programme for promoting gender equality. However, diversity and equal opportunities are an integral part of the recruitment process. Therefore, when we fill positions, we look for someone who will perfectly complement the relevant team, help promote an appropriate mix in terms of gender, nationality and age and have the specific skill set required for the position. We do not distinguish between genders when it comes to compensation (see the Compensation and equal pay section).

The LLB Group has special programmes designed to promote young talent and employees over the age of 50. Flexible working hours models also help promote a work / life balance. The measures listed here are not tied to any predefined timescales.

Flexible working hours and environment

Our flexible working hours models are an important means of increasing diversity. Most employees work under the trust-based working hours model. Under this model, they determine, in consultation with their manager, exactly how their working time is to be structured and different workloads managed. A reduction in workload is possible as well, subject to their managerʼs approval – this also applies to management positions. In addition, employees can increase their holiday entitlement by five or ten days and forego a corresponding amount of pay in return.

Since the autumn of 2020, almost all employees have been able to work from home. Our “Regulation on working from home” provides that employees may work from home for up to 40 per cent of their workload, if their job duties permit it and the legal framework conditions allow it. Differences arise in relation to permissible workloads due to Liechtensteinʼs bilateral agreements with Germany, Austria and Switzerland. We have launched a special programme to help women return to work after childbirth. For example, the workload can be reduced to 60 per cent in the first year, if the employer and employee agree to an 80 per cent arrangement at the end of this period.

We also offer job-sharing models to help people manage their family and working lives. All LLB Group employees are also entitled to take leave for family reasons (100 % of employees with a permanent or temporary employment contract).

We believe that flexible working hours models will help women progress at the LLB Group. Our aim in this way, over the medium to long term, is to reduce the risk of biased decisions through failing to take sufficient account of the perspective of women within the LLB Group.

Young Talents programme, Potential Pools and LEAD

Young adults increase diversity within the bank and make a positive contribution to the corporate culture. They take on responsibility from day one, push ahead with certain issues at their own initiative and provide new ideas and impetus – including in terms of research. With our Young Talents programme, we offer this target group a broad-based training package and insights into operational and strategic activities. This allows young people to realise their potential and identifies ideal candidates for key positions.

For employees with above-average potential, what we call “Potential Pools” have been created. Talented people with considerable potential for development and high levels of motivation are accepted onto the internal Leadership Development Programme (LEAD), which teaches them basic leadership competencies. The aim is provide them with systematic preparation and support on their path toward management roles at the LLB Group.

Initiative for employees 50+

Rapid digital developments and growing complexity are affecting peopleʼs day-to-day experience at work. As a result, job profiles are becoming more demanding. People who are a long way into their career may find it challenging to remain motivated and keep up with the times.

There is a special programme intended to help employees over 50 remain fit for the workplace of the future. This programme includes options for strengthening personal, professional and methodological competence levels. Our “Finanzielle Standortbestimmung zum 50. Geburtstag” (“50^th birthday financial stocktake”) and “Periodische Standortgespräche 56+” (“Regular stocktakes at 56+”) courses are well attended and appreciated. In addition, the “Skills 4.0” course from a leading center of excellence for future-oriented learning in Switzerland provides further education training to meet the needs of the 50+ age group. Two courses from the Liechtenstein Chamber of Commerce and Industry – “Standortbestimmung 50+” (“Stocktake at 50+”) and “Bewusst in einen neuen Lebensabschnitt” (“Entering a new phase of life with confidence”) – which we recommend to our employees, are also proving popular.

Targets and key figures

In order to anchor diversity and equal opportunities more firmly within the business, we have defined measurable targets and key figures as part of our diversity strategy. For example, we have set targets for both the proportion of women in management positions and the generational mix for the years 2026 and 2030. These are not restrictive quotas, but indicators to help us prioritise measures and identify progress.

The targets were set when the diversity strategy was devised. Starting in the summer of 2021, Group Human Resources organised several workshops with the Group Executive Board. The diversity strategy and the associated targets were approved by the Group Executive Board in June 2022 and then presented to the Sustainability Council. The Representation of Employees was informed, but was not involved in devising the targets. Progress towards targets is monitored by the HR or Diversity & Inclusion Cockpit, with no involvement from any employee representatives. Given the low number of female applicants for individual positions, we have made changes to job advertisements in the reporting year in order to make them more appealing to women.

Targets for diversity and equal opportunities

At 41 per cent, the proportion of women at the LLB Group as at 31 December 2024 is higher than the defined target, although it is slightly down on the previous year (31.12.2023: 42 %). Women are still underrepresented in management positions. There has been one woman on the Group Executive Board since 2016, which equates to 20 per cent of the membership (31.12.2023: 20 %). As at 31 December 2024, three women are in senior management roles (31.12.2023: 2), which equates to a 13 per cent share (31.12.2023: 8 %). The seven-member Board of Directors includes two women, which equates to 29 per cent (see the Corporate governance section). The proportion of women in management roles and in positions of responsibility has decreased compared with the previous year. The reason for this decline is the low number of female applicants.

The number of departures of employees aged over 55 remained constant compared to the previous year. We had to make a correction to the 2023 Sustainability Report as the figure stated did not include any people taking early retirement.

In the reporting year, 8.8 per cent (2023: 9.1 %) of the workforce took leave for family reasons: 5.7 per cent of women and 3.1 per cent of men (2023: 5.3 % and 3.8 %). Employees taking leave for family reasons on more than one occasion were only counted once. We based this calculation on the average employee headcount at the LLB Group.

Employees by age group

Further information on employees at the LLB Group can be found in Note 6 to the consolidated financial statements. The key figures in Note 6 differ slightly from the values shown here. This is due to different methods of calculation (as of the reporting date in the Sustainability Statement, average values in the consolidated annual financial statements).

We are taking advantage of the transitional periods for ESRS S1-12 and are therefore disclosing no information about people with disabilities.

Training and skills development

The LLB Group promotes the professional and personal skills of employees through training and professional education. The development of knowledge and skills has a positive impact on the qualification levels of our employees. All employees have the same opportunities to develop further and progress in their career.

Strategy

For the LLB Group, training and professional education are important instruments for increasing its competitiveness. Therefore, we place a lot of emphasis on the continuous advancement of our employees. Our comprehensive professional education programme also makes an important contribution to enhancing employee satisfaction and retention. This helps avoid staff turnover and associated costs. We also expect that equality in relation to training and professional education will help women progress at the LLB Group. This way, we are hoping, over the medium to long term, to reduce the risk of biased decisions though failing to take sufficient account of the perspective of women.

Policies

A separate Group directive “Weiterbildung” (Group directive on “Professional education”) covers the main aspects of professional education and applies to all employees with a permanent or temporary employment contract at the LLB Group. It provides clarity on how the business promotes internal and external professional education measures, in terms of money and time, and sets out the obligations of employees. As a basic principle, any professional education must support business objectives, and the options on offer should also be beneficial to our employeesʼ careers. This Group directive was revised and approved by the Group Executive Board in 2022. Group Learning & Development is responsible for implementation at an operational level. There is a separate regulation for apprentices and those on the Young Talents programme.

Measures

We have two uniform appraisal processes – the “Performance Management Process” (PMP) and the “People Development Process” (PDP) – to support the systematic development of our employees. All employees receive regular appraisals of their performance and their career development. The electronic portal eMap allows them to create a profile containing personal information regarding their ambitions. It also provides them with an overview of courses and of any training they have completed or are planning to undertake. The Group-wide training and professional education programmes are reviewed every year. The LLB Group also draws on employee surveys, which are carried out regularly, to improve its offering.

Professional training and education

Various training and professional education programmes provide our employees with the best possible preparation for their challenging work at a universal bank. These include the following:

• LLB sales academy: this serves as the central for training platform for sales. Its programmes have been specially developed for the LLB Group.
• Client adviser certification: with mandatory SAQ client adviser certification, we are ensuring the outstanding advisory competence of the LLB Group for the long term according to uniform quality criteria.
• Digital learning: LLB uses the new knowledge acquisition possibilities offered by digital learning formats and offers many internal professional education options in the form of webinars. All employees have access to LinkedInʼs entire e-learning offering.
• Professional training: we train young people across many areas. The traditional apprenticeship remains the main pillar of the development programme for our junior employees.

We also offer the Young Talents programme, which provides tailored training for university graduates (see the Young Talents programme, Potential Pools and LEAD section).

Targets and key figures

In the area of training courses and competence development, we want to continuously enhance the technical and personal skills of our employees. Regular professional education is intended to ensure all employees are prepared for new regulatory and changing requirements in the banking sector. We generally expect our employees to prove they have done what was required. Therefore, most internal training courses end with a test, while we tend to obtain examination or attendance certificates for external training courses. The development of technical and personal competencies is also part of the “Performance Management Process” (PMP) and “People Development Process” (PDP): employeesʼ performance is assessed annually, any room for improvement is explored and suitable professional education opportunities are identified.

As the principle of trust-based working hours applies at LLB in Liechtenstein, we have no system for recording the time spent on training and professional education. For this reason, we are taking advantage of the transitional periods for ESRS S1-12 in the reporting year and not reporting any quantitative key figures.

Compensation and equal pay

We place emphasis on fair compensation that explicitly rewards skills and performance. Around two-thirds of our employees receive a variable salary component. Women and men in the same position and at the same performance level are in the same pay scale and wage model.

Strategy

The “Compensation and equal pay” sustainability aspect must be seen in the context of the LLB Groupʼs diversity strategy (see the Diversity of the workforce section). Our aim is to achieve an appropriate gender balance at all levels of the hierarchy. This is why we want to further reduce our gender pay gap. Our key indicator is the Logib ratio, a scientifically based, state-recognised Swiss method for calculating pay equality at companies. As target values for 2026 and 2030, we have defined a Logib ratio of below 5 per cent for each Group company.

Policies

The Group regulation “Vergütungspolitik LLB-Gruppe” (Group regulation on the “Compensation policy of the LLB Group”) defines the framework conditions for the Group-wide compensation policy and places special emphasis on aligning this with risk management. It defines the basis, values and objectives and sets out the minimum requirements for the design of the compensation systems. It also covers reporting within and outside the Group and the respective responsibilities. The Group regulation applies to all permanent and temporary LLB Group employees.

Our key indicator of variable compensation is the “Group Performance Indicator” (GPI). This mechanism allows our employees to share directly in any net profit earned. The Group profit for the last three years – weighted in the ratio 60:30:10 – is used as the basis. The Group Board of Directors has defined a percentage of net profit as a basis for calculating the bonus pool for sharing among employees. This percentage remains constant over the strategy period and is only reviewed in exceptional cases (for example major acquisitions) (for more information, see the Compensation policy section).

Three factors are relevant for determining individual target compensation:

• the personʼs position, along with the associated expectations, difficulties and demands;
• individual performance, which has a direct influence on the bonus;
• alignment with the respective location.

Employees may also take part of the variable component of overall compensation, providing it exceeds EUR 50ʼ000, in share entitlements or shares. These shares may be deferred for a period of four years. During this time, the entitlements may be revoked or reduced in certain circumstances. In the event of serious violations such as fraud or gross negligence, bonuses already paid may be clawed back.

The Group Board of Directors is responsible for the Group regulation on compensation policy. It also decides on the compensation level for its members. The Group Nomination & Compensation Committee provides it with advice. An individual target compensation level is defined for each member of the Group Executive Board (see the Compensation report section). Neither the Representation of Employees nor any other employees were involved in devising the compensation policy or the targets.

Measures

The Group Executive Board has devised an equal pay initiative based on the LLB Schweiz Logib ratio for 2021 (see the section below). The aim of this initiative was to develop guidelines for the 2024 wage round. As part of this wage round, managers at the LLB Group were urged to place a greater focus on the gender pay gap within their teams. In particular, they were encouraged to check female employeesʼ salaries with a view to identifying and rectifying any differences.

Every three years, LLB Österreich drafts a gender pay report in line with regulatory requirements and presents this to the Board of Directors. This then assesses whether the requirements of a gender-neutral compensation policy have been satisfied. The report is produced in collaboration with a well-known consultancy firm and is not made public.

No additional measures are currently planned. Pay equality is reviewed on a regular basis. If any inequalities are expected, a further analysis is performed as to whether and what further steps can be taken.

Targets and key figures

Our key indicator for measuring pay equality is the Logib ratio. The calculation is performed with the help of a publicly accessible online tool. As at 31 December 2024, our Logib ratio is 4.8 per cent, which means, in the reporting year, it is already below the target of 5 per cent we wanted to achieve in 2026. The calculation only incorporated employees in Liechtenstein and Switzerland, which equates to more than three-quarters of LLB Group employees. LLB Österreich is checking whether this calculation should be performed in future too.

The Logib ratio uses a different calculation method to the gender pay gap ratio envisaged under the ESRS. We calculate this key figure as well, although it has no relevance in terms of managing the sustainability aspect. As at 31 December 2024, the Group-wide figure under this alternative calculation method is 33.0 per cent (31.12.2023: 33.1 %). A major reason for the gender pay gap, using the ESRS calculation method, is the low proportion of female managers. In addition, unlike the Logib ratio, no account is taken of factors such as years of service, level of training / education, expectations or the position held.

Since 2022, as a further performance indicator, we have been measuring the ratio of the salary of the highest-earning person within the business to the median salary of the other employees. As at 31 December 2024, this ratio amounts to 11.6 (31.12.2023: 11.3). The change compared with the figure for 2023 is due to a change in the calculation method. Calculations for the entire LLB Group were performed in Swiss francs (conversion rates for EUR and AED as at 31.12.2024). These were based on 100 per cent of total target compensation as at 31 December 2024. This consists of both fixed and variable components for those employees with an entitlement to variable compensation elements. The variable elements may also include shares, if the personʼs contract envisages this.

We are committed to paying all employees an appropriate level of remuneration. Suitable benchmarks are available in Germany (Minimum Wage Act) and Austria (implemented under the collective agreement system). Our employees at these locations receive appropriate remuneration in line with statutory requirements. There are no statutory benchmarks in Liechtenstein or Switzerland, so we use 60 per cent of median salary in the respective country as the threshold. All LLB Group employees exceed this value. In the UAE, there are no statutory or LLB internal thresholds. We do, however, makes sure we pay appropriate and competitive salaries there.

Measures against discrimination, harassment and violence

An important element in ensuring diversity and equal opportunities within the business is effective protection against discrimination, harassment and violence. We at the LLB Group adopt a zero-tolerance policy in this regard.

Strategy

The LLB Group takes account of all national statutory requirements relating to discrimination at its respective locations. In Liechtenstein, the Criminal Code (section 283 StGB) prohibits the public denigration or defamation of people on account of characteristics such as skin colour, language, nationality, ethnicity, religion or outlook, gender, disability, age or sexual orientation. It is also forbidden to bar people from using generally accessible services because of these characteristics. In addition, there is a Gender Equality Act in Liechtenstein, which is specifically intended to promote gender equality at work, in order to prevent any form of gender-based discrimination. Among other things, it covers equality in relation to recruitment, working conditions and career progression. Companies in Liechtenstein must ensure there is no discrimination in the workplace or in the provision of services. This includes measures to promote equality and the avoidance of any adverse treatment on account of the characteristics referred to.

In Austria, we comply with the requirements of the Equal Treatment Act (GlBG), which prohibits discrimination in the workplace and against those accessing services on account of gender, ethnicity, religion, age or sexual orientation. In Switzerland, employees are protected against gender-specific discrimination and adverse treatment by things like the Gender Equality Act and the Employment Act. The UAE has no comprehensive anti-discrimination legislation, although the “Federal Decree Law No. 2 of 2015 on Combating Discrimination and Hatred” was passed in 2015. This prohibits any discrimination and hate speech on account of religion, belief, denomination, race, skin colour and ethnic origin.

Policies

Our Code of Conduct prohibits any form of discrimination, harassment or bullying. This explicitly states that the LLB Group offers all employees the same opportunities in terms of recruitment and promotion, regardless of gender, age, religion, nationality, ethnic background, sexual orientation, marital or family status and physical ability levels. The additional characteristics of race, skin colour, political opinion and social origin listed in the ESRS have not been explicitly included in the Code of Conduct as our list is only intended for illustration purposes and does not claim to be exhaustive. Our commitment to basic equality and our condemnation of any form of discrimination are not affected by this.

The Code of Conduct is binding for all LLB Group employees and may be consulted by them and external stakeholders at any time via the corporate website. By consistently implementing the Code, we create a safe, respectful working environment based on mutual trust and appreciation. Violations and wrongdoing are punished consistently and proportionately. Therefore, the Code provides a reliable framework for all employees and bodies. Group Legal & Regulatory is responsible for the content. The Group Human Resources organisational unit is responsible for measures against violence and harassment. The Integrity Committee discusses and defines these measures (for more information on the Code of Conduct and Integrity Committee, see the Corporate governance and integrity section).

Measures

We regard all measures for promoting diversity in the workforce (see the Diversity of the workforce section) as prevention of discrimination. In addition, by having at least two, or generally three, people present during recruitment interviews, we ensure that candidates are assessed as objectively as possible. When members of the Board of Management are appointed and elections for the Board of Directors are held, the nominating committee also checks that candidates are treated the same and afforded equal opportunities and ensures the principle of non-discrimination is observed.

In the reporting year, we have thoroughly revised our Code of Conduct (see the Corporate governance and integrity section).

Targets and key figures

We have not yet devised or defined any quantitative targets for this sustainability aspect. From a qualitative perspective, we are endeavouring, in line with our zero-tolerance policy, to keep confirmed cases of discrimination, including harassment, and the number of complaints and financial penalties as low as possible. In the reporting year, no cases of discrimination, including harassment, were registered, no complaints were recorded and no financial penalties were imposed on the LLB Group.