Governance and ethics

Setting the foundation for trusted and responsible business

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 
  • 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 and 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 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.   

  The Board has adopted guidelines for director recruitment and board composition with the goal of recruiting 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 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 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 and French and we are working on translating it into seven additional languages by the end of 2025. 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 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 it 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 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 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.   

Sun Life manages many human rights elements across our business – including in our employment practices, products and services, supply chain and investment decision-making processes. Our commitment to respecting fundamental human rights is supported by policies on employment equity, health and safety, harassment and discrimination, and procurement in various regions. These policies help guide our people, as well as suppliers, in respecting human rights and applicable laws. To ensure we are aware of and manage the full range of potential human rights issues, we have worked to assess, map and prioritize key human rights risks across our global organization. Our evaluations are guided by the UN Guiding Principles on Business and Human Rights. 

Learn more in our Code of Conduct

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.  

2024 highlights

  • 98% of employees completed annual Code of Conduct training2
  • Assessed 100% of critical suppliers to evaluate their alignment with our Supplier Code of Conduct
  • Provided education on climate transition plans and transition finance to the Board of Directors

Learn more about our progress and performance in our 2024 Sustainability Report and Sustainability Performance Tables

1All 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.

2Training completion rates are as at January 15 since annual training assigned during the reporting year may be completed after year-end.

Refer to Sustainability Data Scope.