Code of Conduct and Ethics Hotline

Code of Conduct

Sun Life is in the business of helping our Clients achieve lifetime financial security and live healthier lives. Our reputation and success are based on our shared commitment to doing the right thing for our Clients, our shareholders, society and each other. Our Code of Conduct (our Code) acts as a roadmap to help keep us on track across everything we do.

The Code helps us maintain our reputation for corporate integrity as a trusted and responsible business. It outlines our expectations to act with honesty, integrity and professionalism in all that we do. As a global company, our Code reflects the diversity of our organisation and is available in multiple languages. For additional information about other languages, please email the Code office: Code@sunlife.com / Regles@sunlife.com. 

Read Sun Life’s Code of Conduct.

Ethics Hotline

Our Ethics Hotline is managed by an external service provider (ClearView Connects™) and is available 24/7 from anywhere in the world. ClearView provides the Ethics Hotline reporting platform, while Sun Life handles the review and investigation of any reports submitted through that platform.

The Ethics Hotline is available to report a possible violation of our Code that could harm our Clients, our employees or members of the public, as well as Sun Life or our reputation. 

You can submit an Ethics Hotline report:

• online through a web-based application;
• by calling the Ethics Hotline and giving your report verbally to an agent;
• by leaving a voicemail report; or
• by mailing a report to a confidential Post Office (P.O.) Box.

What can be reported through the Ethics Hotline?

Topics that can be reported include (but are not limited to):

• Activity against Clients; agent misconduct
• Bribery, corruption or kickbacks
• Conflict of interest
• Discrimination
• Diversity, equity and inclusion issues
• Fair treatment of client concerns
• Fraudulent or inaccurate accounting, auditing or financial reporting
• Harassment
• Harm to people (including human trafficking, forced labour or child labour) or property
• Health, safety and environment concerns
• Improper gifts or gratuities
• Insider trading
• Intimidation and retaliation (whistleblower protection)
• Manipulation or falsification of data
• Misuse of Sun Life assets (IT, information, property)
• Risks that threaten our integrity and security, including by way of foreign interference
• Theft, embezzlement or fraud
• Violations of laws or regulation, or of our policies or procedures

What should not be reported to the Ethics Hotline?

You should not use the Ethics Hotline for:

• Client inquiries
• Customer service complaints
• Donation or partnership inquires
• Media relation inquiries
• Product and services inquiries (insurance, investments, financial advice, asset management)
• Regional office inquiries
• Shareholder or investor inquires
• Sun Life career opportunity inquiries

Submitting a report:

When submitting a report, you’ll be asked to provide the details of the possible violation. Please provide as much information as you can as that will help to facilitate the investigation. For example: Who are the parties involved? What happened that caused you concern? When did the events occur? Where did the events occur (e.g. email, phone call, in person, etc.)? How were you or others impacted? 

Online reporting:

Submit a report online through www.clearviewconnects.com. 100% anonymity is maintained unless you choose to provide your contact information. Your report will be automatically encrypted, and your IP address will not be tracked. ClearView Connects™ uses the latest version of encryption technology to protect your identity.

Toll-free numbers:

To locate the toll-free number for your country see the ClearView Reporting Guide. When you call, you will be connected to an automated menu. You may also request service in your preferred language. Depending on the language selected, it may take a few minutes for a translator to connect with you.

Mailing a report:

Reports can be mailed to ClearView Connects, P.O. Box 11017, Toronto, Ontario, M1E 1N0, which is only available to ClearView personnel. Anything received by mail is transcribed into the ClearView system and all hard copies are destroyed.

What happens when you use the Ethics Hotline? 

Once your report is submitted, you will be provided with a Report ID, a password, and instructions on how to check for status updates online. Your completed report is sent to the Sun Life Code Office, where it is assigned to the appropriate Senior Compliance Officer, or their delegate, who will begin an investigation and enter status updates online.

To follow up on your Report ID, call the Ethics Hotline number or login to the website to view both the history of the issue (as described by you), any follow-ups and the response provided. You may also add additional details to the report – this will help facilitate the investigation. Please be aware that specific details of the investigation or outcomes may not be shared or disclosed because of privacy or confidentiality concerns. 

Our commitment against intimidation & retaliation:

Sun Life does not tolerate any form of intimidation or retaliation for reporting possible violations of our Code or participating in a review or investigation. If you report a possible breach, no action will be taken against you, even if we cannot confirm the breach. However, a mischievous or malicious allegation of a breach is itself counter to our Code. Anyone who attempts in any way to intimidate or retaliate against someone who reports a possible breach of the Code or participates in a review or investigation will face disciplinary action, up to and including termination of employment, regardless of their position. Companies and consultants acting on behalf of Sun Life are expected to adhere to the values of our Code and failure to do so may result in termination of any agreements with Sun Life and legal action.

Additional information about the Ethics Hotline reporting process can be found in the ClearView Reporting Guide.