Governance and ethics

Empowering our people to do the right thing

Good governance and behaviour are essential for any sustainable business. They’re especially important for financial services companies like ours. Sun Life’s reputation depends on being well-governed and behaving ethically at all levels of our organization. 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
  • Tenure and renewal
  • Board diversity
  • Board development and assessment
  • Strategic planning and risk management oversight
  • Succession planning and talent management
  • Shareholder engagement and alignment

Our approach to good governance starts at the top with our Board. Including the Chair of the Board, 11 of our 12 Board members are independent. This structure helps to ensure that we address the long-term interests of 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 Sustainability Governance.

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 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. All employees and Board members must complete annual training and declare their compliance with the Code.

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. 

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 on our intranet in four languages and on demand in other languages.

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 hotline to seek guidance and report misconduct anonymously. Our enterprise compliance team monitors and investigates reports to the Ethics Hotline.

We engage with governments and regulators in public policy discussions to share our views and those of our Clients, employees and communities on issues relevant to our business. 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

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

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. As a practice, we will not make any Corporate financial contributions or donations to any political parties, factions or candidates for public office.


  • Balanced gender representation on our Board of Directors by 2025

    On track – 42% women (FY21)

2021 highlights

  • 42% of Board members self-identify as women; 25% of Board members self-identify as belonging to an underrepresented group1; 50% of Board committee chairs self-identify as women
  • 4 languages make our Code of Conduct more accessible to employees worldwide. It’s now on our intranet in English, French, Vietnamese and Indonesian Bahasa.

Learn more about our progress and performance in our 2021 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