Trevian Asset Management Oy – Anti-Bribery Principles
1. Fundamental Principle
Trevian does not accept direct or indirect bribery, corruption, or unethical influence in any form. Bribery is defined as offering or accepting money, gifts, loans, payments, rewards, or any other benefit with the intention of improperly influencing the actions or decisions of another party, or of inducing an illegal act or other breach of business conduct. This also applies to benefits that are seemingly given to a private individual but in practice are granted based on the individual’s position at Trevian.
The purpose of these principles is to prevent bribery in all its forms and to promote a transparent and ethical operating culture. These principles apply to all Trevian employees, the Managing Director, and the Board of Directors.
2. Gifts and Hospitality
Giving or receiving gifts and hospitality is permitted only when it is reasonable, customary in business, and does not create obligations or expectations. Gifts and hospitality must be transparent, justified by a legitimate business purpose, and in line with Trevian’s ethical guidelines. Gifts and hospitality must be occasional between the same giver and recipient, and their value must not exceed the limits set in these guidelines.
At Trevian, the guiding value limit for gifts and hospitality is EUR 100. Giving gifts or hospitality to public officials requires separate approval from the Managing Director. If the value of a gift or benefit exceeds EUR 100, the employee must obtain approval from their line manager and, if necessary, assess the matter together with the Chief Compliance Officer (CCO). The approval must be documented in writing and attached to the invoice, and all exceedances must be reported to the CCO.
The anti-bribery guidelines and policies of clients and other stakeholders, as well as the recipient’s right to refuse a gift, must always be respected. Gifts or hospitality must not be given or accepted during tendering processes or contract negotiations.
3. Client and Representation Trips
If an employee is invited to an event organized by an external party outside their normal area of operation, participation requires the approval of the employee line manager. In the assessment, the principles concerning gifts and hospitality are applied, as well as the relevance of the event to business activities, such as strengthening the company’s image or enhancing client and stakeholder relationships.
Trevian will cover at least the travel and accommodation expenses related to the trip and, where necessary, other reasonable costs. Representation of events related to business activities may be organized at the company’s expense, provided that the level of hospitality is reasonable in relation to the nature of the event. Such events must not raise doubts about the integrity of Trevian’s operations, and whenever possible, several client and stakeholder representatives should be invited at the same time. Participants’ travel expenses are not reimbursed unless there are particularly exceptional reasons.
4. Public and Societal Engagement
Charitable donations or donations to socially significant causes are made by decision of the Managing Director. Donations are given without conditions or expectations of any reciprocal benefit to Trevian’s operations.
5. Monitoring and Reporting
Any activity that is contrary to these principles is always investigated by the employee’s line manager. Where necessary, the CCO and the Head of Human Resources participate in the investigation. Any violations are reported immediately to the Managing Director.
The CCO reports on compliance with the anti-bribery principles to the Managing Director and the Board of Directors as part of Trevian’s sustainability reporting
Approved by the Board of Directors of Trevian on 23 February 2026.