Abstract
Abstract This article considers the ongoing work and application of the Hague Conference on Private International Law (HCCH) Convention of 1 July 1985 on the Law Applicable to Trusts and on their Recognition (Trusts Convention). The article analyses fiduciary duties found across the trusts legislation and draft legislation of selected common and civil law jurisdictions. The commonalities of fiduciary duties across jurisdictions are presented here to provide a foundation for discussion among legal experts regarding their possible future inclusion in the HCCH Trusts Convention or in supporting materials developed by the HCCH as a list of fiduciary duties. Such a list of duties would foster certainty and predictability for those involved in legal relationships created by trusts.
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