Business Principles

As a provider of financial products and services, Triton plays an important role in society. In order to fulfill this role, it needs to maintain the confidence of its customers, alliance partners, employees, and other stakeholders by acting with professionalism and integrity. Triton attaches paramount importance to upholding its reputation, and the Triton Business Principles play an important role in this respect. Triton expects the highest levels of integrity from its employees, regardless of their position in the organization.

The Triton Business Principles are:

• We are committed to our integrity.
• We aim for an above average return.
• We are open and clear in our communications.
• We respect each other.
• We are involved in our communities.

We are committed to our integrity

Triton expects the highest levels of personal conduct by all its employees, whatever their position. It is acknowledged that all effective business relationships, inside as well as outside Triton, depend on honesty, integrity and fairness. A Triton employee…

• Respects the rule of law and abides by all applicable laws and regulations.
• Avoids doing business with any individual, company or institution if that business is connected with activities which are illegal or which could be regarded as unethical.
• Handles information with care. In particular, the security and confidentiality of all proprietary information and data processing, including customers’ personal confidential information, must be safeguarded in accordance with applicable laws and regulations. Proper and complete records must be made of all transactions on behalf of Triton.
• Does not accept gifts or personal benefits in connection with a business relationship as a result of which he/she might appear to be under an obligation.
• Does not accept or solicit personal offers or payments, nor does he/she makes such offers or payments to third parties. Bribery of any form is unacceptable.
• Avoids any contacts that might lead to, suggest or create an appearance of conflict of interest between personal activities and the business of the Group.
• May not enter into – and must avoid the appearance of engaging in – securities transactions based on inside information or misuse of confidential information.

We aim for an above average return

As a commercial organization, we believe that we must provide an above average return for our clients. We support the market economy as the most effective means to achieve the best returns for our customers, investors and employees. However, the best markets flourish only within an ethical framework. No one at Triton may disparage a competitor, or use unethical means to obtain any advantage for Triton.

We are open and clear in our communications

Within the bounds of commercial confidentiality, we attach great importance to open and transparent communications with all our stakeholders. Triton makes every effort to ensure full, complete, fair, accurate, timely and understandable disclosures in reports and documents we file with or submit to our regulators, as well as in other public communications we make. For our customers we endeavor to provide clarity in the value and condition of our investment products and services.

We respect each other

Respect for the individual is the basis for all contacts between Triton and its stakeholders. Triton encourages diversity by creating an environment where everyone has the opportunity to fully participate in achieving business and personal success, and is valued for his or her distinctiveness. We feel that our management and staff should reflect our customer base and the local communities where we are active. That is why our personnel policy is based on equal opportunities and a non-discriminatory policy. Personal career development for everyone at Triton is encouraged. Triton aims to provide all its employees with safe conditions of work and competitive terms of employment.

We are involved in our communities

Good relations with local communities are fundamental to Triton’s long-term success. Our community relations are based on mutual trust, respect and active partnership. We demonstrate our commitment by making donations, sponsoring and supporting numerous social activities. All Triton employees are encouraged to play a positive role in community activities. Triton is a commercial organization and our activities are business oriented. Therefore Triton does not intervene in political matters, nor do Triton companies make gifts or donations to political parties or candidates for political office. However, within the legitimate role of business, through all available, legitimate means and after careful consideration, Triton reserves the right to speak out on matters that affect our businesses, employees, shareholders, and/or customers. In countries where there is a legal framework to do so, Triton reserves the right to facilitate employee contributions to political parties or candidates for political office.

Responsibilities

• The Business Principles apply to the whole of Triton, its subsidiaries and business units and to every employee.
• It is the responsibility of all those in authority at Triton to ensure that these Principles are fully communicated to all present and future staff. They must also ensure that these are strictly observed.
• The members of the Executive Board and all Managers are responsible for applying the Business Principles within their areas of responsibility.
• The Executive Board continually reviews on the effective operation of the Business Principles.

Compliance to Business Principles

• Every individual at Triton is required to act in accordance with both the letter and spirit of these Business Principles and obliged to promptly report any violation of these Principles to his/her line manager or our Compliance Officer.
• Triton employees will be held accountable for acting in accordance with the Business Principles.
• Upon violation of the Business Principles, disciplinary measures may be taken, up to and including termination of employment.
• Violations of these Business Principles will be promptly disclosed to the extent required by the applicable laws, rules and regulations.