Governance and ethics

Good governance fosters effective decision-making by providing a framework of transparency and accountability. This structure supports decision-making that is well-informed, aligned with our strategy and risk appetite, and resilient to change. We apply strong corporate governance processes and practices that cover areas such as:

• director independence
• board composition
• board orientation, continuing education and assessment
• strategic planning and risk management oversight
• succession planning and talent management
• shareholder engagement and responsiveness
• shareholder alignment through director share ownership requirements
• board renewal, including director tenure

Good governance starts with our Board of Directors. Sun Life’s Board is composed of qualified  members with a broad range of business and strategic experience. All Board members except for our President & CEO are independent, including the Chair of the Board. This structure supports strong oversight and effective decision-making to drive long-term sustainable value for the benefit of our stakeholders. The Board is committed to continuous improvement and adapts its practices to meet evolving  regulatory and market expectations.

The Board has adopted guidelines for director recruitment and board composition with the goal of attracting highly qualified directors with the right complement of skills, experience and perspectives to allow the Board to best fulfil its mandate.

We expect everyone¹ representing Sun Life to behave ethically and responsibly, take accountability for their actions, and comply with applicable laws where we operate. It’s not just about following rules and policies. It’s about doing the right thing and empowering our people to maintain our commitment to high standards of business ethics and integrity.

Our Code of Conduct (the Code) helps guide us and sets clear expectations for our behaviour, how we conduct our business and how we make decisions. We review the Code annually, with an in-depth review at least every three years. These reviews help ensure the Code is updated to capture emerging topics in the current environment and reflect evolving industry standards. As a global company, our Code reflects our dedication to building an empowered and inclusive culture, operating as a trusted and responsible business, and delivering on our Purpose of helping Clients achieve lifetime financial security and live healthier lives. The Code is available in English, French and seven additional languages upon request. All employees and Board members must complete annual training and declare their compliance with the Code.

We have a framework of controls, policies and programs to support the Code and to prevent and detect corruption. These elements help us meet legal and regulatory requirements and protect our business, employees and Clients. We also have a separate process for dealing with charitable and philanthropic spending, which requires that all charitable donations are reported and go through our donation approval framework.

We’re committed to complying with the letter and the spirit of anti-corruption and anti-bribery laws in the countries where we operate. It’s our policy to never engage in any form of bribery or corruption and to report potential violations immediately.

Our Code promotes speaking up and outlines our commitment against intimidation and retaliation. Employees and Board members are required to report all known and suspected Code breaches. There are multiple channels to report Code breaches including through an employee’s manager, Human Resources, a member of the Legal or Compliance team, the Code inbox and the Ethics Hotline. Our Ethics Hotline is available 24/7 in multiple languages and empowers all our employees to play an active role in protecting the organization. Employees and the general public can use the Ethics Hotline to seek guidance and report allegations of misconduct anonymously. The Code Office monitors, tracks and reports on Code breaches and their resolution to senior management and select Board committees quarterly.

Public policy is essential for Sun Life to fulfill its Purpose. We proactively engage with policymakers and regulators on policy issues related to our Purpose. We do this both directly and through our participation in industry associations, including the:

• Canadian Life and Health Insurance Association 
• American Council of Life Insurers 
• Hong Kong Federation of Insurers
• Philippine Life Insurance Association, Inc.

Wherever we operate, we comply with local lobbying laws and regulations. Our Compliance Risk Management Framework and Prevention of Bribery and Corruption Operating Guidelines, supported by our Code, set out clear rules and restrictions for engaging with politicians and government officials.

You’ll find highlights of our public policy activities throughout our Sustainability Report.