ANTI-BRIBERY POLICY

Trevian does not tolerate direct or indirect bribery, corruption, or unethical influencing of any kind. A bribe is considered to be the offering or receiving of money, a gift, a loan, a payment, a reward or some other benefit if its purpose is to get the bribe taker to favour the bribe giver or to have an illegal act or other offence committed in the company’s business. This also applies to situations where an employee is offered a benefit seemingly as a private person, but in reality, is based on his/her position at Trevian Asset Management Oy. 

The purpose of the anti-bribery policy is to strive to prevent all forms of bribery and to promote a culture of anti-bribery. The anti-bribery policy concerns all Trevian employees, the CEO and the Board of Directors. 

Our values:
working together, courage, ability to listen to the client, independence, and responsibility

Principles for giving and receiving gifts and hospitality 

A Trevian´s employee may give or receive a gift or hospitality if it is appropriate with respect to the client relationship. 

Normal and reasonable gifts without an expectation of reciprocity are part of doing business and interacting with clients and partners. 

Gifts and hospitality are acceptable if they meet the following criteria: 

  • they do not create any obligations or expectations on the recipient; 
  • they are offered openly, as a token of appreciation or for a genuine business purpose; 
  • receiving them can stand up to public scrutiny;  
  • receiving a gift or hospitality is not in conflict with Trevian Asset Management Oy’s Code of Conduct; 
  • the giving or receiving of gifts is not frequent between the giver and the recipient;  
  • the monetary value of the gift or hospitality does not exceed the value cap. 

At Trevian Asset Management Oy, the value cap on a gift or hospitality is EUR 100, for public officials any gift or hospitality is possible only with a separate CEO approval. If the gift or benefit offered/given exceeds the limit, employees must seek their supervisor’s approval. The situation can be assessed with the Chief Compliance Officer (CCO) if necessary. If the supervisor approves the proposal, the written approval is attached to the relevant invoice. All gifts and hospitality that exceed EUR 100 must always be reported to the CCO.

We always respect our clients’ and stakeholders’ anti-bribery guidelines and policies as well as the recipient’s right to refuse a gift. 

Gifts or hospitality may not be given or received during competitive bidding processes or during collaboration or agreement negotiations. 

Client events and trips 

If a Trevian`s employee is invited to a client or hospitality event organised by a third party outside the area in which he or she works, attendance always requires the permission of a supervisor. The principles of accepting gifts and hospitality set out above must be taken into account when assessing the fair value of attending the event. Attendance must also be justifiably related to Trevian Asset Management Oy’s business, either to reinforce the company’s corporate image or to strengthen relationships with a client or stakeholder. 

Trevian pays at least the travel and accommodation costs arising from the trip, and other expenses, as necessary. 

Hospitality events may be organised at Trevian Asset Management Oy’s expense if they are justifiably organised for a purpose related to its business, either to reinforce the company’s corporate image or to strengthen relationships with a client or stakeholder. Hospitality must be proportionate to the nature and purpose of the event and not give rise to doubts about the integrity of the activities. As far as possible, representatives of different client and stakeholders should be invited to the event at the same time. The attendees’ travel costs related to such events are not compensated unless there are exceptional reasons. 

Charitable sponsorships and donations 

Decisions on donations to charity or activities intended to promote a good cause are made by the CEO. Trevian Asset Management Oy’s donations are made without any conditions or expectations of profit.  

Monitoring compliance with the policy 

Actions in violation of this policy are always investigated by a supervisor. The CCO and the HR Director are involved in the investigation if necessary. 

Any non-compliance must be reported to the CEO without delay. 

The CCO reports on compliance with the anti-bribery policy to the CEO and to the Trevian`s Board of Directors as part of compliance reporting. 

Approved by Trevian Asset Management Oy Board of Directors on 22 February 2023.