Governance and ethics

Empowering our people to do the right thing

Good governance and behaviour are essential practices for any sustainable business. They’re especially important for financial services companies like ours. Being well-governed and behaving ethically at all levels of our organization is critical to Sun Life’s reputation. These practices are essential to ensuring we operate – and are regarded – as a trusted and responsible business.

Our approach

We apply strong corporate governance processes and practices that cover areas such as:

  • director independence
  • board composition and diversity
  • 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

Good governance starts with our Board of Directors. Sun Life’s Board is composed of qualified and experienced members from diverse backgrounds. Including the Chair of the Board, 11 of our 12 Board members are independent. This structure drives effective decision-making and long-term, sustainable value creation for our stakeholders. By focusing on continuous improvement, the Board ensures that Sun Life stays on top of changing regulatory and market expectations. 

Our Board Diversity Policy considers gender, gender identity, age, ethnicity, sexual orientation, disability and geography. The Board aims to have 35% to 45% directors who self-identify as women as it progresses towards an aim of balanced gender representation by 2025. The Board also aims for representation by underrepresented groups1 of 20% to 25% on the Board. To learn more about our diversity efforts, refer to Diversity, Equity and Inclusion

The Board also oversees our sustainability agenda – refer to our sustainability governance model

We expect everyone2 representing Sun Life to behave responsibly. And we expect them to take accountability for their actions and comply with applicable laws wherever we operate. It’s not just about following rules and policies. It’s about doing the right thing and empowering our people to model an ethical culture. 

Our Code of Conduct (the Code) is a compass for how we conduct our business. It sets clear standards for proper behaviour. We review the Code annually, with an in-depth review at least every three years. These reviews help us stay relevant with emerging topics in the current environment and reflect evolving industry standards. As a global company, our Code reflects the diversity of our organization and is available in nine languages. All employees and Board members must complete annual training and declare their compliance with the Code.

We have a robust framework of controls, policies and programs to support the Code and to prevent and detect all forms of corruption. These elements help us meet legal and regulatory requirements and protect our business, employees and Clients.

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 it outlines our commitment against retaliation. Employees and Board members are required to report all known and suspected Code breaches. The Code Office monitors, tracks and reports on possible Code matters. 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 stakeholders to play an active role in protecting the organization. Employees and the general public can use the Ethics Hotline to seek guidance and report misconduct anonymously. Our Enterprise Compliance team monitors and investigates reports to the Ethics Hotline. 

Sun Life manages many human rights elements across our business – in our employment practices, products and services, supply chain, and investments. To ensure we are aware of and manage the full range of potential human rights issues, in 2022 we worked to assess, map and prioritize key human rights risks across our global organization. Over the year, we intend to strengthen our approach to managing key human rights issues.

Learn more in Diversity, Equity and Inclusion.

Public policy is essential for Sun Life to fulfill its Purpose. We proactively engage with policymakers and regulators on policy discussions related to our Purpose, including climate change. 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

Our Government and Regulatory Affairs group works closely with the Sustainability team and business units across Sun Life, to ensure that our lobbying and advocacy activities support our Purpose and advance our sustainability commitments. Wherever we operate, we comply with local lobbying laws and regulations. We’re committed to being transparent about our public policy positions and activities. 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.


  • Balanced gender representation on our Board of Directors by 2025

    Achieved – 50% of Board members self-identify as women (Q1’23)

  • 20% to 25% representation by underrepresented groups1 on our Board of Directors

    Achieved – 25% of Board members self-identify as members of underrepresented groups (Q1’23)

2022 highlights

  • Assessed 100% of critical suppliers to evaluate their alignment with our Supplier Code of Conduct
  • Advocated for improved sustainability-related disclosures including better climate-related financial disclosures 

Learn more about our progress and performance in our 2022 Sustainability Report and ESG Performance Tables.

1 Individuals who have self-identified as members of the Black, Indigenous, People of Colour, disabled and/or LGBTQ2+ communities.

2 All employees, Board members, external directors of Sun Life and their subsidiaries and controlled joint venture companies, and third parties acting on our behalf or representing us.

Refer to Sustainability Data Scope.