CODE OF CONDUCT

Trevian is the leading commercial real estate investment and asset management company in Finland. We comply with applicable laws and regulations in all our operations. Trevian Asset Management Oy’s Code of Conduct complements the applicable laws and regulations and describes how we operate.  

Every employee of Trevian Asset Management Oy is familiar with the Code of Conduct and complies with the Code. Training in the Code of Conduct is part of the induction process at the start of employment, and our employees are regularly trained to keep their skills up to date. Our corporate responsible approach is based on our values, which are working together, courage, ability to listen to the client, independence and responsibility. Trevian Asset Management Oy has no political or religious affiliations.  

The Code of Conduct was approved by Trevian Asset Management Oy’s Board of Directors on 19 November 2019, the update on 23 March.2021, 17 February 2022 and on 22 February 2023.

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

We operate responsibly 

Responsibility is one of Trevian Asset Management Oy’s values and a natural part of how we run our day-to-day business. For Trevian Asset Management Oy, responsible business means that we take into account the economic, social and ecological impacts of our operations. 

Our core mission is to optimise the risk reward ratio for our investors’ property investments; this can be achieved through responsible choices and practices. Our Due Diligence processes aim to highlight themes related to responsibility, and we want to be our investor clients’ partner in responsibility issues. 

As asset managers, we are actively involved in urban development projects on behalf of our investor clients as the existing urban structure is developed and supplemented in terms of both commercial and residential premises.  

We train all of our staff members on responsibility issues on a regular basis. We commit new employees to comply with Trevian Asset Management Oy’s Code of Conduct and operating instructions. 

In our operations, we aim to take into account Finland’s goals of becoming carbon neutral in 2035. 

Climate change mitigation 

Environmental considerations and climate change mitigation play an important part in both our own operations and the properties we manage. We develop our practices while listening to the expectations of our employees, clients and stakeholders. Transparency and open communications are important to us. 

When it comes to investors, we primarily look for properties that are centrally located with good transport links, and we prefer properties that are accessible by public transport. 

We develop the properties under our management in accordance with the instructions from the investors and on a long-term basis. We are committed to complying with and promoting environmental, social and good governance aspects in our property management operations. 

When it comes to renovation design projects, we employ the best designers in the industry with the best resources to execute them; designers who are committed to maintaining high health and safety standards. In our renovation projects, we aim to reduce emissions from construction and remove substances that are harmful to the environment wherever possible.  

We aim to take into account climate change-related risks to properties in our ongoing maintenance activities, renovation designs and projects; examples include increasingly frequent extreme weather events such as storms, repeated rainstorms, flooding and rising sea levels. 

We are always looking for ways to improve the environmental performance of the properties we manage by reducing greenhouse gas emissions, the use of energy and water as well as the volume of waste throughout our operations. We aim to increase the use of renewable energy, such as geothermal energy, in the properties we manage, and our goal is to reduce water consumption in our property portfolio. 

Life-cycle sustainability, energy efficiency and reduced carbon footprint are highlighted in our design guidelines for constructing new buildings for investors.  

Waste from the use and construction of properties is sorted and raw materials are recycled whenever possible.  

We help tenants in our investors’ properties to reduce their energy consumption and improve their working conditions. We also make residential properties more comfortable and we ensure that the premises are safe for tenants, employees and visitors alike. 

We respect workers’ and human rights  

Trevian Asset Management Oy is committed to promoting human rights and operating in accordance with the UN human rights principles. We comply with international agreements and standards, the most important of which are the ILO labour conventions. We respect our employees’ right to equality, non-discrimination and freedom of association. We condemn all forms of use of child labour, forced labour and other practices that violate human rights. We require that our partners operate according to the same principles.  

Competent staff at the heart of our operations 

Trevian Asset Management Oy’s success is based on highly-skilled employees and staff well-being. Trevian Asset Management Oy’s goal is to be a responsible employer; an equal workplace in which discrimination, bullying and harassment are not acceptable. Inappropriate behaviour and harassment will be addressed without exception and may result in a reprimand, warning or, ultimately, termination of employment. The implementation of equality and non-discrimination policies is regularly monitored through measures such as staff surveys.  

Our executives and supervisors put the principles of responsible HR management into practice and follow a jointly agreed management process. 

Bribery is prohibited 

Bribery is strictly prohibited in all Trevian Asset Management activities. Trevian Asset Management Oy does not accept direct or indirect bribery, corruption or unethical influencing of any kind.  

Trevian Asset Management Oy’s employees do not offer third parties or receive gifts, payments, hospitality or other benefits intended to influence decision-making. Gifts given and received must not compromise the independence of the giver or the recipient.  

For more details, please see: Trevian Asset Management Oy’s Anti-bribery policy 

Avoiding conflicts of interest 

Trevian Asset Management Oy has guidelines in place for the identification and prevention of potential conflicts of interest. These guidelines have been approved by Trevian Asset Management Oy’s Board of Directors. 

A conflict of interest refers to an exceptional situation in relation to the provision of a service between a client and Trevian Asset Management Oy, for example, which may involve a significant risk to the client’s interests. 

A conflict of interest may also arise between Trevian Asset Management Oy and its employee or between two clients. Conflicts of interest may arise in the provision or performance of all Trevian Asset Management Oy’s services. 

Trevian Asset Management Oy seeks to prevent potential conflicts of interest that may pose a significant risk to the interests of the client by means that are considered reasonable. Potential conflicts of interest are primarily identified and prevented proactively by various organisational and administrative measures. The steps taken vary according to the business or service in question. The measures include Chinese walls in certain areas, which means restricting employees’ access to client data, for example. The measures aim to ensure that Trevian Asset Management Oy’s executives and employees perform their duties with loyalty and execute transactions with sufficient independence to protect Trevian Asset Management Oy’s best interest and the interests of our clients.  

If a conflict of interest arises, the nature of and reasons for the conflict of interest must be explained to the client prior to the execution of a transaction. The client will then independently consider whether to go ahead with the transaction despite the conflict of interest. The transaction in question can also be cancelled in order to avoid a conflict of interest. 

In order to avoid risks related to conflicts of interest, including the occurrence of a conflict of interest, Trevian Asset Management Oy employees are obliged to disclose any actual or potential conflicts of interest by informing their supervisor or the Chief Compliance Officer (CCO), who will then resolve the conflict, as necessary.  

Combatting the shadow economy 

Trevian Asset Management Oy supports conditions for honest work and business activities and is committed to combatting the shadow economy. The shadow economy refers to legal business activities for which no statutory payments or taxes are made. Trevian Asset Management Oy works closely with various operators in the construction industry. There is a large shadow economy in the construction sector due to the prevalence of using subcontractors and its chain-like processes. 

Trevian Asset Management Oy complies with the Act on the Contractor’s Obligations and Liability when Work is Contracted Out. The act also applies to repair, upkeep and maintenance activities, not just construction. In order to combat the shadow economy, contracts are not concluded until Trevian Asset Management Oy has received the documents required by law and they confirm that the contractor fulfils its legal obligations as a contractor and employer. 

Prevention of money laundering and terrorist financing 

Money laundering is usually defined as business arrangements whereby funds deriving from illegal activities are introduced to the legal monetary system in efforts to hide the origin of the funds. Trevian Asset Management Oy employees may not, under any circumstances, take part in any operations or activities that are, or appear to be, related to money laundering. 

We comply with existing sanctions for money laundering and terrorist financing. Trevian Asset Management Oy’s clients are identified when the client relationship is established, and any changes in the clients’ activities are monitored throughout the duration of the relationship so that the company can detect any exceptional transactions.  

For more details, please see: Trevian Asset Management Oy’s guidelines for the prevention of money laundering and terrorist financing 

Data protection and security as part of responsible operations  

Consideration of data protection and data security in all activities is part of Trevian Asset Management Oy’s responsibility. We process confidential information in accordance with law and good data management practices. Confidential information includes details such as our clients’ and employees’ personal data as well as information related to transactions and the financial standing of our clients and partners. This information is processed only by those Trevian Asset Management Oy employees whose duties require them to do so.  

We follow the guidelines on confidentiality, data protection and data security. We maintain the legality of our activities and the competence of our staff in data security and data protection by means such as regular staff training.  

For more information about personal data processing, please see Trevian Asset Management Oy’s Privacy policy. 

Adherence to the Code of Conduct – our partners 

Trevian Asset Management Oy requires that its partners respect and adhere to this Code of Conduct. Any violation of the principles of the Code of Conduct is considered a serious and material breach of contract and may result in termination of collaboration and liability for damages. 

Implementation of the Code of Conduct and organisation of the responsibility function 

The Board of Directors of Trevian Asset Management Oy approves responsibility policies. The CEO has the overall responsibility and is responsible for the implementation of the policies approved by the Board of Directors.  

Trevian Asset Management Oy’s responsibility function is managed by the Chief Compliance Officer (CCO), who leads the Compliance team. The CCO reports to the CEO on responsibility activities and provides separate reports on the various areas of responsibility and progress, as necessary.  

The key duties of the responsibility function are to support Trevian’s executives and operations: 

  • in risk management related to the operating environment;   
  • by monitoring compliance with laws, decrees and regulations; 
  • by monitoring the compliance with internal guidelines and procedures; and 
  • by contributing to the development of internal controls. 

Business directors and supervisors are responsible for implementing the practical measures. Shared services (finance, IT, HR, communications) support the operations in achieving responsibility goals.  

Whistleblowing procedure 

Trevian Asset Management Oy does not condone illegal or unethical activities and we encourage our employees, clients, and stakeholders to report any infringements.  

If you have noticed or suspect that Trevian Asset Management Oy’s Code of Conduct has been violated, please contact Trevian Asset Management Oy’s Chief Compliance Officer (CCO) or the Compliance Team without delay. All concerns and reports regarding compliance with the Code and the guidelines will be treated in confidence, with care and treating all parties equally. 

For more details, please see Trevian Asset Management Whistleblowing policy