What are the key projects that you have been involved in over the past 12 months?

Over the past 12 months, I have been involved in many projects in our sector, with the most critical ones being related to ESG, DORA and Instant Payments Regulation.

Starting with DORA, we had to adopt a range of strategies, tools and best practices to strengthen further our organisation’s digital resilience, despite the multifaceted impact on the banking sector. Key compliance strategies and tools adopted by our bank, include, amongst others, the development and implementation of a comprehensive ICT risk management policy and the identification, assessment and mitigation of ICT-related risks regularly, the establishment of procedures to detect, classify and report ICT-related incidents, the maintenance of a register of ICT service providers and the assessment of their resilience by performing third-party vendor assessments, ensuring that contracts include clear obligations for security, reporting and compliance with DORA and lastly the assignment of clear responsibilities to senior management and the board of directors for ICT risk oversight.

Moving on to ESG, we have established an ESG Strategy by choosing areas of focus in alignment with our Bank’s business strategy and we set strategic goals, targets and actions to be implemented by the end of the year. Such targets include the reduction of energy use, waste reduction, support green and sustainable projects through financing, promote employee well-being and enhance professional development, build a culture of trust, integrity, and ethical behaviour within the organisation, ensure accountability and oversight of the board of directors and ensure compliance with all applicable laws and regulations.

Lastly, Instant Payments Regulation is a significant legislative development aimed at modernising payment systems and making instant payments, i.e. sending and receiving euro-denominated instant payments at any time, with funds arising in 10 seconds or less. The IPR is offering strategic opportunities for banks as it will enable them to compete with fintechs, with both pros and cons being present.

How can general counsel foster a corporate culture that supports ESG principles and compliance across all levels of the organisation?

General counsel plays a crucial strategic role in embedding ESG principles into the corporate culture and ensuring alignment with compliance obligations. General counsel can foster such culture across all levels of the organisation. This includes, amongst others, ensuring ESG is on the board agenda and support directors in understanding ESG risks and opportunities, work closely with the senior management of the organisation to embed ESG in strategy and operations, promote ethical decision-making and a risk-aware culture in all legal and business communications, draft or refine codes of conduct, supplier codes, environmental policies, frameworks and whistleblowing mechanisms with clear ESG references, integrate ESG risks into the risk management framework, equip teams with an understanding of ESG-related regulations, stay ahead of evolving ESG regulations and ensure the business understands its legal obligations, oversee accuracy and consistency in sustainability reports, investor communications, and marketing materials and include ESG clauses in contracts with suppliers, i.e. commitments to human rights, emissions targets, or diversity hiring.

Based on your experiences in the past year, are there any trends in the legal or business world that you are keeping an eye on, of which you think other in-house lawyers should be mindful?

During the last year, we have observed a significant evolution in the corporate and regulatory environment, marked by a heightened focus on the effectiveness and integrity of corporate governance arrangements. This shift reflects not only increasing regulatory scrutiny, but also the growing expectations of investors, stakeholders, and the public for greater accountability, transparency, and ethical leadership at all levels of the organisation.

Given this context, it is essential that legal professionals across the organisation remain attuned to the structure, function, and quality of governance mechanisms. This includes board composition and responsibilities, internal controls, reporting frameworks, and the alignment of governance practices with strategic objectives and sustainability goals.

The legal function must proactively support the development and continuous improvement of governance frameworks, ensuring they are compliant with applicable laws and regulations, responsive to emerging risks, and reflective of best practices in corporate conduct. By doing so, lawyers not only mitigate legal and reputational risk but also contribute to the organisation’s long-term resilience and value creation.