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Exhibit
14.1
 WESTERN LIBERTY BANCORP
 CODE OF ETHICS
     Approved by Board of Directors November, 2010




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CODE OF ETHICS
  
 PAGEIntroduction
    
    
    1Distribution, Training, and Verification of Receipt
    
    
    1Applicability of Code to Directors
    
    
    1Individual Activities
    
    
    1Personal Conduct
    
    
    1Personal Financial Responsibility
    
    
    2Personal Investments
    
    
    2Fair Dealing
    
    
    3Complying With Law
    
    
    3Anti-Competitive Activities
    
    
    3Conflicts and Self-Dealing
    
    
    4Corporate Opportunity
    
    
    4Conflicts of Interest
    
    
    4Outside Employment
    
    
    5Directors and Officers of Other Companies
    
    
    5Directors and Officers of Civic and Charitable Organizations
    
    
    6Self-Dealing
    
    
    6Bequests or Legacies
    
    
    6Fiduciary Relationships
    
    
    6Gifts and Business Entertainment
    
    
    6Confidentiality
    
    
    8Confidential Information
    
    
    8Confidential Information About the Company
    
    
    8Insider Trading in Securities
    
    
    8Confidential Information About Past and Present Employees
    
    
    9Employee Activities
    
    
    9Solicitation and Distribution Activities
    
    
    9Protection and Proper Use of Company Assets
    
    
    9Political Activities
    
    
    9Advice to Customers
    
    
    10Speeches and Articles for Publication
    
    
    11Blogs and Other Internet Postings
    
    
    11Indebtedness, Gambling, Firearms, and Other Conduct
    
    
    11Financial Reporting
    
    
    11Code of Ethics for Principal Executive and Financial Officers
    
    
    11Public Disclosures
    
    
    12
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Compliance With Code, Reporting, Monitoring
    
    
    12Accounting Complaints
    
    
    12Violations of Code and Reporting
    
    
    12No Retaliation
    
    
    13Monitoring Code Compliance
    
    
    13Fidelity Bond Coverage
    
    
    13Waivers for Executive Officers or Directors
    
    
    13Records Retention
    
    
    13Important Contact Information
    
    
    14
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Western Liberty Bancorp
Code of Ethics
 
 Introduction
  i.e. st
 
 Distribution, Training, and Verification of Receipt
  
 Applicability of Code to Directors
  
 Individual Activities
 
 Personal Conduct




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Personal Financial Responsibility
   
    
    Borrowing money from other staff members.
    
    Borrowing money from customers other than those that are lending institutions.
    
    Borrowing at a preferential rate from the Bank because of your position.
   
 Personal Investments
    
    
    Real or personal property in which the Company has or intends to obtain an
ownership interest (e.g., through purchase, foreclosure, repossession, or in a
fiduciary capacity).
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
    
    Stocks, bonds, or other securities about which you have or could be expected to
have confidential information (e.g., a proposed merger involving a customer).
    
    Trust deeds, mortgages, or chattel mortgages that create a security interest in
property in which the Company or the Bank has a security interest.
    
    An interest in any business entity that is a customer or supplier of the
Company. This limitation does not apply to directors who are not officers of the
Company or to ownership of the stock of any public company by an employee who does not
possess confidential information about such company.
    
    An interest in a company for which you are the account officer.
 
 Fair Dealing
   
 Complying With Law
   
 Anti-Competitive Activities
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e.g.
 
 Conflicts and Self-Dealing
 
 Corporate Opportunity
  
 Conflicts of Interest
  
    
    A known direct or indirect financial interest including a joint venture or
directorship in or with a supplier, customer, or prospective customer without approval
in writing by an executive officer of the Company. This prohibition does not apply to
a directorship with a not-for-profit organization that is a customer or prospective
customer of the Company.
    
    Personal investments in a customers or a suppliers business.
    
    Receiving preferential treatment from customers, suppliers, or prospective
customers because of your position with the Company. Any appearance of impropriety
must be scrupulously avoided.
    
    Selling or leasing goods or services to the Company without prior disclosure to
and approval in writing by an executive officer. In addition, the terms and
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conditions of any such transaction must not be more favorable than those offered to
others.
    
    Receiving discounts on personal purchases from suppliers or customers because
of their business relationships with the Company.
  
 Outside Employment
   
    
    Employment by a company or personally engaging in any activity that is
competitive with the Company.
    
    Employment that involves the use of the Companys equipment, supplies, or
facilities.
    
    Employment that involves the preparation, audit, or certification of
statements, tax returns, or other documents upon which the Company may place reliance
for lending or other purposes. If you prepare income tax returns of individuals or
entities other than yourself, you must obtain confirmation from your potential client
that the client does not intend to use your work product as part of any transaction
with the Company.
    
    Employment that involves the rendering of investment, legal, or other advice,
or exercising judgment that is based upon information, reports, or analyses that are
accessible primarily from or through your employment with the Company.
    
    Employment that may reflect adversely on you or on the Company.
    
    Employment under circumstances that may suggest the sponsorship or support of
the Company on behalf of the outside employer or an outside organization.
    
    Employment as an insurance or securities broker, agent, or representative.
    
    Employment as a real estate contractor, salesman, broker, or agent.
 
 Directors and Officers of Other Companies
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Directors and Officers of Civic and Charitable Organizations
  
 Self-Dealing
    
 Bequests or Legacies
  
 Fiduciary Relationships
  
 Gifts and Business Entertainment
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
    
    Acceptance of gifts, gratuities, amenities, or favors based upon family or
personal relationships (e.g.,from a parent, child, or spouse of an employee of the
Company) when the circumstances make it clear that those relationships, rather than the
business of the Company, are the motivating factors.
    
    Acceptance of meals, refreshments, travel arrangements, accommodations, or
entertainment, all of reasonable value, in the regular course of a meeting or other
occasion, the purpose of which is to hold bona fide business discussions or to foster
better business relationships; provided that any such expenses would have been a
legitimate business expense paid by the Company if not paid by another party.
    
    Acceptance of loans from other banks or financial institutions on customary
terms to finance proper and usual activities, such as home mortgage loans, automobile
loans, or other consumer purpose loans, except where prohibited by law.
    
    Acceptance of advertising or promotional material of nominal value, such as
pens, pencils, note pads, key chains, calendars, and similar items.
    
    Acceptance of discounts or rebates on merchandise or services that do not
exceed those available to other customers.
    
    Acceptance of civic, charitable, educational, or religious organizational
awards for recognition of service and accomplishment.
  7




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Confidentiality
 
 Confidential Information
  
 Confidential Information about the Company
   
 Insider Trading in Securities
  8




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Confidential Information About Past and Present Employees
   
 Employee Activities
 
 Solicitation and Distribution Activities
  
 Protection and Proper Use of Company Assets
  
 Political Activities
 e.g.
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Advice to Customers
   10




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Speeches and Articles for Publication
   
 Blogs and Other Internet Postings
  
 Indebtedness, Gambling, Firearms, and Other Conduct
  
 Financial Reporting
 
 Code of Ethics for Financial Professionals
  11




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Public Disclosures
  
 Compliance With Code, Reporting, Monitoring
 
 Accounting Complaints
   
 Violations of Code and Reporting
   12




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No Retaliation
  
 Monitoring Code Compliance
  
 Fidelity Bond Coverage
  
 Waivers for Executive Officers or Directors
  
 Records Retention
  13




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Important Contact Information
   14




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CODE OF ETHICS CERTIFICATION FORM
  Signature:
 Name and Title:
 Date:
   
  
  
  
  
  
  
  
  
  
  
  
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APPENDIX
 WESTERN LIBERTY BANCORP
CODE OF ETHICS FOR FINANCIAL PROFESSIONALS
 GENERAL PHILOSOPHY
  CODE OF ETHICS FOR FINANCIAL PROFESSIONALS
  
    
    Engage in and promote honest and ethical conduct, including the ethical handling of actual
or apparent conflicts of interest between personal and professional relationships;
    
    Avoid conflicts of interest and disclose any material transaction or relationship that
reasonably could be expected to give rise to such a conflict;
    
    Comply with applicable laws, rules, and regulations of federal, state, and local
governments (both United States and foreign) and other appropriate private and public
regulatory agencies;
    
    Act in good faith, with due care, competence, and diligence, without misrepresenting
material facts or allowing independent judgment to be subordinated;
    
    Take all reasonable measures to protect the confidentiality of non-public information
about Western Liberty Bancorp, its subsidiaries, and their customers, and to prevent the
unauthorized disclosure of such information unless required by applicable law or regulation
or legal or regulatory process;
    
    Produce full, fair, accurate, timely, and understandable disclosure in reports and
documents that Western Liberty Bancorp or its subsidiaries files with, or submits to, the
Securities and Exchange Commission and other regulators and in other public communications
made by Western Liberty Bancorp or its subsidiaries;
    
    Proactively promote ethical and honest behavior within Western Liberty Bancorps
environment;




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APPENDIX
 
    
    Assure responsible use of and control of all assets, resources, and information of Western
Liberty Bancorp; and
    
    Promptly report any possible violation of this Code of Ethics for Financial Professionals
to the Corporate Governance and Nominating Committee.
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APPENDIX
 Western Liberty Bancorp Code of Ethics for Financial Professionals