Trevian Asset Management Oy – Whistleblowing
Purpose of the Whistleblowing Guidelines
The purpose of these Whistleblowing Guidelines is to encourage employees of Trevian Asset Management Oy, as well as individuals dealing with the company, to report any observed or suspected misconduct, violations, or potential criminal activities. Reports enable appropriate investigations to be initiated and help prevent or correct wrongdoing.
1. What Can Be Reported?
Suspected misconduct may include:
– serious violations of law, or
– actions that are contrary to the values and ethical guidelines of Trevian Asset Management Oy,
which may have a harmful impact on the company, its clients, or its partners.
Examples of reportable misconduct include:
– accepting gifts or hospitality contrary to company guidelines
– misuse of insider information
– disclosure of client data or confidential information without justification
– conflicts of interest and situations causing bias in decision-making
2. Handling of Reports
At Trevian Asset Management Oy, whistleblowing reports are handled by the Compliance Team, led by the Chief Compliance Officer (CCO). All reports are treated confidentially and are handled only by persons who have a necessary role in investigating the matter.
3. Protection of the Whistleblower
If the whistleblower acts in good faith and raises a genuine concern, reporting will not result in any sanctions or personal disadvantages for the whistleblower, even if the suspicion later proves to be unfounded.
4. Rights of the Parties Concerned
The rights of individuals concerned by a report are governed by applicable data protection legislation. The parties concerned have the right to:
– access information relating to them, and
– request the rectification of incorrect, incomplete, or outdated data.
5. How to Make a Report
If an employee or another person dealing with Trevian Asset Management Oy observes or suspects conduct that conflicts with the company’s values or ethical business principles, a report can be made as follows:
Employees:
– Report to line manager, HR, or the Chief Compliance Officer (CCO)
– Anonymously via the intranet: Whistleblower channel
External parties:
– Anonymously via Trevian’s website: Ethical channel or whistleblower channel
Approved by the Board of Directors of Trevian Asset Management Oy on 23 February 2026.