Trevian Asset Management Oy – Code of Conduct
1. Introduction
Trevian is a Finnish commercial real estate investment and asset management company. We provide domestic and international clients with full-service asset management and structured investment services throughout the entire investment lifecycle. Our mission is to ensure that the use, maintenance, and development of properties under our management are carried out responsibly, ethically, and in accordance with the principles of sustainable development.
These Code of Ethics and Business Conduct define the fundamental principles guiding our operations and complement applicable legislation. The guidelines apply to all employees of Trevian as well as to all partners and service providers with whom we work.
Trevian’s values – collaboration, courage, listening to the client, independence, and responsibility – guide both our strategic decision-making and our day-to-day operations. Our objective is to build
trust with our stakeholders and to promote transparency, responsibility, and long-term success.
2. Governance Model and Responsibilities
– The Board of Directors approves the Code of Ethics and Business Conduct and the
sustainability (ESG) objectives and metrics annually. The Board monitors the
implementation and development of these guidelines.
– The Chief Executive Officer (CEO) is responsible for the implementation of the guidelines and bears overall responsibility for sustainability.
– The Chief Compliance Officer (CCO) leads the compliance function, oversees
compliance with laws, regulations, and internal policies, coordinates the handling of ethical breaches, and reports to the Board and the CEO.
– The Chief Sustainability Officer (CSO) leads the ESG strategy and reporting. The CSO is responsible for sustainability reporting, coordinates sustainability work, and reports to the Board and the CEO.
– Business unit leaders and supervisors are responsible for practical implementation.
Shared services (finance, IT, HR, communications) support the achievement of objectives.
3. Key Sustainability Themes
Trevian’s key sustainability themes were defined based on a double materiality assessment conducted in August 2025. The assessment was carried out through workshops, stakeholder interviews, and expert evaluations, providing a comprehensive view of both external and internal expectations.
The double materiality assessment identified sustainability topics that are significant both from an environmental and societal perspective and from a financial perspective for Trevian’s business and stakeholders.
3.1 Climate Change and Energy Efficiency
Trevian’s role as a real estate asset manager is central to promoting energy efficiency and mitigating climate change. We influence the use and maintenance of properties in cooperation with owners and tenants. We encourage energy-efficient solutions, support the transition to carbon-free energy, and help ensure the management of climate risks related to properties.
We collect and provide owners and tenants with the data they require, such as energy consumption and emissions, to support their sustainability reporting.
3.2 Safety, Accessibility, and Inclusivity
We ensure that the premises we manage are safe, accessible, and usable by all. We conduct audits and user surveys, respond to identified deficiencies, and develop facilities in cooperation with tenants. Special attention is paid to accessibility and inclusivity so that all user groups can use the properties safely and comfortably.
3.3 Circular Economy and Waste Management
We promote recycling and resource efficiency in properties. We provide diverse waste sorting solutions and communicate circular economy practices to tenants and owners. We continuously develop data collection and reporting to ensure that owners and tenants receive the information they need, for example regarding waste management and recycling.
3.4 Stakeholder Communication and Data Management
We respond to the information needs of owners, tenants, and financiers regarding sustainability matters. We develop data collection and reporting, listen to stakeholder expectations, and tailor KPIs to their needs. We actively communicate about sustainability efforts and collect feedback from stakeholders.
3.5 Risk Management
Risk management is essential from the perspective of property owners. We ensure that risk management covers both operational and strategic aspects. We carry out climate risk assessments at the property level and take risks into account in all activities, including contracts, partner selection, and client cooperation.
Risk management is an integral part of daily decision-making and responsible management.
3.6 Biodiversity
Our ability to influence biodiversity is limited, but we take it into account whenever possible, for example in major renovations and land-use planning. We actively monitor industry developments and communicate the importance of biodiversity and related topical issues to owners and tenants.
4. Human Rights and Working Life Principles
Trevian is committed to promoting human rights and operating in accordance with the United Nations’ human rights principles. We comply with international agreements and standards, most notably the ILO conventions on working life.
We respect the equality, non-discrimination, and freedom of association of our employees. We condemn the use of child labor, forced labor, and all other practices that violate human rights in any form. We require our partners to operate in accordance with the same principles.
5. Social Responsibility and Personnel
We take comprehensive care of the physical and mental well-being of our personnel, recognizing the importance of well-being for both individuals and the community. We provide extensive and high-quality occupational health services that enable preventive support and rapid response to health-related challenges.
We actively promote equality and diversity in our workplace and foster an open and respectful atmosphere for all.
Our principles related to equality, diversity, and inclusion are set out in a separate DEI (Diversity, Equity & Inclusion) Policy, which guides our operations and decision-making. The policy defines concrete objectives and measures to ensure non-discrimination, equality, and equal opportunities
for all employees to participate and have an impact. It supports daily work and guides the development of a workplace where diverse backgrounds, perspectives, and competencies are seen as strengths.
We handle personal data and confidential information carefully in accordance with applicable legislation and best practices, ensuring data protection and employee trust. We intervene immediately and consistently in cases of inappropriate behavior or harassment, promoting a safe and fair working environment for everyone.
6. Anti-Bribery and Zero Tolerance
The company does not accept direct or indirect bribery, corruption, or improper influence under any circumstances. Trevian applies zero tolerance to bribery and avoids any situations where the possibility of bribery could even arise.
Employees must not offer or accept gifts, payments, hospitality, or other benefits intended to influence decision-making or create dependencies.
To prevent and identify bribery, Trevian has detailed internal guidelines based on the principles of transparency, independence, and ethics. These guidelines emphasize that employees must act prudently and responsibly in all situations where gifts or benefits could give rise to misunderstandings or dependencies. Every employee is required to familiarize themselves with these principles and comply with them consistently in all activities.
7. Measures to Avoid Conflicts of Interest
Trevian Asset Management Oy recognizes that conflicts of interest may arise, for example, between the company, an employee, and a client, or between two clients. A conflict of interest refers to a situation where Trevian’s or an employee’s personal, financial, or other interests may conflict with a client’s interests or affect impartial decision-making.
Our operating principle is to identify and prevent conflicts of interest as early as possible. This is achieved through organizational and administrative measures, such as restricting access rights to client information and applying so-called “Chinese wall” arrangements.
If a conflict of interest arises, it must be reported without delay to a supervisor or the CCO, who will assess the situation and decide on the necessary measures.
Clients are always provided with sufficient information about the nature and reasons for the conflict of interest before a transaction is carried out, enabling them to make an informed decision. If necessary, the transaction may be discontinued to avoid the conflict of interest.
Trevian has issued separate internal guidelines on conflict of interest management, which all employees are required to follow.
8. Combating the Grey Economy
Trevian strongly supports the conditions for honest work and business operations and is systematically committed to combating the grey economy in all its activities. The company strictly complies with the Act on the Contractor’s Obligations and Liability when Work is Contracted Out (1233/2006) and is registered in the Reliable Partner service, demonstrating our commitment to transparency and reliability.
Contracts are never concluded before all legally required reports have been properly obtained and carefully reviewed.
Trevian requires the same responsible operating model from its partners, ensuring that all parties act in accordance with ethical principles and that the risks of the grey economy are minimized. In this way, we build trust with clients, partners, and society – honesty, transparency, and responsibility are the cornerstones of our operations.
9. Prevention of Money Laundering and Terrorist Financing
Trevian Asset Management Oy strictly complies with applicable legislation on the prevention of money laundering and terrorist financing, as well as related sanctions and regulatory guidelines.
At the start of every client relationship, a thorough KYC (Know Your Customer) process is conducted to verify client background information, identify beneficial owners, and determine the risk profile. We use a dedicated KYC system that enables proper data storage and systematic monitoring of PEP lists (Politically Exposed Persons) and sanctions.
Client activities are continuously monitored throughout the client relationship, and any unusual activity is addressed immediately. Suspicious transactions are reported to a supervisor or the CCO. All collected information is appropriately documented and updated as necessary.
Our personnel receive regular training to ensure they are able to identify and prevent risks related to money laundering and terrorist financing.
10. Data Protection and Information Security
We process confidential information in accordance with applicable laws and good data management practices.
Trevian has strong technical and administrative controls in place to ensure information security. These include encrypted connections, multi-factor authentication, role-based access management, and regular information security audits. In addition, systems are in place to monitor data processing and alert to deviations.
We comply with comprehensive internal policies and guidelines on data protection and information security. The Data Protection Policy defines how personal data is collected, processed, stored, and disposed of in accordance with the law and the EU General Data Protection Regulation (GDPR). The Information Security Policy guides the technical and organizational measures used to protect the company’s information and systems against unauthorized access, damage, or loss.
Any data breaches or data protection risks are reported immediately and handled in accordance with predefined procedures.
Personnel participate in regular information security training to ensure their competence remains up to date and potential information security gaps are identified quickly. Training ensures that employees are familiar with current security practices and know how to act correctly in various information security situations.
11. Partners and Suppliers
We require our partners to respect and comply with these ethical business principles.
Sustainability requirements are included in contracts, and audits may be carried out where necessary.
Violation of the Code of Ethics and Business Conduct constitutes a serious breach of contract and may result in termination of cooperation or liability for damages.
12. Stakeholder Cooperation and Communication
We communicate openly and regularly about our sustainability work to owners, tenants, and all other key stakeholders. We consider active and transparent communication to be a vital part of our corporate culture, as it builds trust and promotes shared responsibility.
We encourage feedback, and all reports are handled with strict confidentiality and due care.
Any unethical conduct can be reported directly to the CCO or anonymously through the whistleblowing channel. Each report is investigated thoroughly to ensure that our ethical principles are implemented in practice
13. Implementation and Monitoring
The Board of Directors approves these guidelines annually. The CCO and CSO are responsible for their implementation and monitoring. Ethical guidelines and sustainability principles are part of employee onboarding and continuous training.
Approved by the Board of Directors of Trevian Asset Management Oy on 23 February 2026.