Sun Life Grepa is committed to leading with integrity and takes breaches of the Code seriously. We all play an active role in ensuring the Code is applied throughout Sun Life Grepa and that breaches of the Code are handled appropriately.

How do I report a breach of the Code?

If you need guidance or not sure on how to apply the letter and spirit of the Code in any situation, or if you would like to report a possible breach of the Code, you can:

• Talk to: Your People Leader/Manager, a member of your local Compliance team, a member of your local Human Resources department, a member of the Legal team
• Email: Sun Life Code Office at Code@sunlife.com
• Submit your concerns anonymously through the Ethics Hotline at www.clearviewconnects.com

Sun Life Grepa does not tolerate any form of intimidation or retaliation against employees for reporting possible breaches of the 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 a breach of our Code.

Gifts and hospitality are generally recognized as important parts of doing business, developing business relationships and building goodwill. It’s a two-way street. You cannot accept any benefit that may in any way influence, or appear to influence, your judgement or ability to make objective business decisions. You also cannot offer gifts, favors, benefits or hospitality that may be perceived as inappropriately influencing another party’s business dealings with Sun Life Grepa.

Consider the following questions when accepting from or offering to external parties any gifts, favors, hospitality, or other benefits:

• Is it an unaccepted business practice in the region?
• Is the value involved more than nominal and reasonable?
• Does this occur frequently?
• Would doing so make it difficult to make a fair and unbiased business decision?
• Would it embarrass Sun Life Grepa or the recipient if publicly disclosed?
• Does it violate our internal anti-bribery and anti-corruption policies or processes, including local policies?

We may only give or accept gifts that are customary, modest, and culturally sensitive. Cash gifts or equivalents, such as stored value cards that can be converted to cash, securities, cheques, money orders or loans, are prohibited. Gift certificates or gift cards are allowed provided they are modest in value, not ordinarily convertible to cash, and are in-line with established local thresholds.

Depending on your jurisdiction or position at Sun Life Grepa, you can also have an obligation to report or seek pre-approval of gifts and hospitality.

Special laws and record keeping requirements apply to gifts and hospitality when dealing with government officials or individuals tied to state-owned or controlled enterprises. Using personal funds or any third-party funds (e.g., outside counsel, consultant) to purchase gifts and hospitality for government officials is prohibited unless approved by Management. Consult with your People Leader before offering or extending gifts and hospitality to government officials.

One important way we demonstrate our integrity in doing business is by ensuring that we each act in the best interests of Sun Life Grepa, our Clients and shareholders. We are committed to not putting our own personal interests ahead of Sun Life Grepa, our Clients and shareholders, and avoid activities that can harm or reflect negatively on any of them. That’s why it’s important to avoid conflicts of interest, whether they are actual or potential conflicts of interest, including the appearance of one.

Many situations could give rise to a potential conflict of interest where our judgment or ability to act can be compromised. Actions we take on behalf of Sun Life Grepa cannot be influenced by the possibility of gain for ourselves or for anyone personally associated with us – that would be a conflict of interest.

Examples of situations that could give rise to a conflict of interest and must be disclosed include the following:

• Circumstances or relationships that give rise to a potential conflict of interest where our judgment or ability to act can be compromised.
• Direct reporting responsibility over a family member or significant other.
• Business relationship with a family member or significant other, or a business in which they are materially involved.
• Client relationship whereby you are asked to act as a trustee, agent, power of attorney or executor (excludes family member).
• Consulting directly or indirectly with current or potential Sun Life Grepa suppliers.

Also, employees may receive paid or unpaid requests from intermediaries on behalf of undisclosed industry third parties to take part in meetings and discuss general business matters within their area of expertise. These requests can create a conflict of interest and risk disclosing confidential business information to competitors and must be declined.

Our sustainability ambition is to maximize our positive impact and ensure the resiliency of our organization, in support of our Purpose. Our sustainability plan builds from our foundation as a trusted and responsible business. We aspire to be a responsibly managed business that is Client-focused, competitive, forward-thinking and sustainable for the long term. We aim to create competitive advantage and differentiation for our business through the following focus areas of our sustainability plan:

Increasing Financial Security: We aspire to increase the lifetime financial security of our Clients, employees and communities. We’re increasing access to and use of insurance and wealth products, and empowering and educating people to improve financial security outcomes.

Fostering Healthier Lives: We aspire to improve health and wellness outcomes for our Clients, employees and communities. We’re improving access to and use of health insurance and health care, and empowering people to navigate and manage their health journey to improve health outcomes. Our investments in community health complement these efforts.

Advancing Sustainable Investing: We aspire to deliver sustainable returns for Clients and drive the transition to a low-carbon, inclusive economy. We manage assets with material environmental, social and governance (ESG) issues integrated in our investment processes and offer our Clients sustainable investing opportunities. In addition, we invest our own assets in ways that support a low-carbon and more inclusive economy.

Climate change: We are committed to being part of the climate solution. We’re decarbonizing our business and engaging with our stakeholders to support the transition to a low-carbon economy. Meaningful climate action is essential to achieving our Purpose and ensuring the resiliency of our business.

We are committed to actively protecting our products and services from being used for money laundering, financing terrorists or other criminal activity, and protecting the integrity of both Sun Life Grepa and the financial systems in the countries in which we operate.

Deterring, detecting and preventing money laundering or terrorist financing activity is everyone’s accountability and requires each of us to:

• Know our Clients through verifying their identity, authenticating them each time they interact with us, and monitoring our business relationship with them
• Be aware of and be able to identify and report any suspicious, unusual premiums, deposits, payments, surrenders or other activities to your local Money Laundering Reporting Officer

For additional information on your obligations to help combat money laundering and terrorist financing, seek guidance from your local Money Laundering Reporting Officer or the Sun Life Grepa Chief Anti-Money Laundering Officer.

One of our obligations as a trusted and responsible business is to support our industry and encourage fair competition. Although we compete vigorously in every market in which we participate, we are committed to conducting business in compliance with all competition and antitrust laws which prohibit Sun Life Grepa from engaging in activities intended to restrict or lessen competition.

This means we cannot make agreements with competitors to fix prices or allocate sales, Clients or territories. We cannot discuss with outsiders’ strategic information on topics such as pricing, product development and Client lists. Even if we do not intend these discussions to result in actions that restrict or lessen competition, these discussions could be interpreted that way, and could be illegal whether or not they lead to restricting or lessening of competition.

Competing fairly and ethically in all our business activities is the most effective way to avoid contravening the prohibitions found in these various laws.

When approached for information by an external party, we must follow the procedures established for our business unit. This includes escalating the inquiry for response to our leader and local Compliance or Legal team, as appropriate. We cooperate with lawful investigations and inquiries by regulators, law enforcement agencies, external and internal auditors and investigators acting on behalf of Sun Life Grepa.

• We must provide them with accurate and factual information and cannot mislead or attempt to improperly influence them.
• We cannot tamper with any document to obscure the true nature of a transaction in Sun Life Grepa’s records or to impede or influence an audit, regulatory review or investigation.

If you suspect information is not being provided as required, report your concerns.

Sun Life Grepa does not tolerate fraud. We will not participate in any type of dishonest or fraudulent behavior that can affect our Clients, colleagues, shareholders, Sun Life Grepa, or our reputation and brand.

Fraud is a dishonest act or omission intended to deceive or mislead for personal or corporate gain. Some examples of fraudulent acts include:

• Forgery or alterations of a document or cheque
• Submission of a false or fictitious claim forecharges or services that were not actually incurred
• Submission of a fabricated invoice for goods or services not received
• Bribes and economic extortion
• Misuse of confidential information

In addition to the application of systems and processes to help detect and deter fraudulent activity, all employees should speak up and report any fraud or other suspicious activity, whether committed by a colleague or a third party.

An important component of employee engagement relates to our ability to participate in our communities. We encourage you to be involved with outside organizations, charitable activities, and the political process, provided your involvement does not create or appear to create a conflict of interest or interfere with your ability to carry out your responsibilities at Sun Life Grepa; this can include a second job or serving on a board. When participating in activities unrelated to your work at Sun Life Grepa, you are expected to avoid any activity that might compromise Sun Life Grepa or our brand and reputation.

In particular, you cannot engage in the following activities without the prior written approval from an Executive level manager and your business group’s General Counsel:

• Serve on the Board of Directors of any company or organization that is publicly traded, competes with or has a business relationship with Sun Life Grepa in the insurance, health, wealth and asset management sectors; or
•  Be employed by or consult for any company or organization that competes with or has a business relationship with Sun Life Grepa in any of those same sectors.

Consult with your People Leader, local Compliance team, Human Resources, a member of the Legal team or email the Sun Life Code Office before accepting employment at a business or joining the board of any company or organization that might pose a conflict of interest. Otherwise, a second job or board position must be kept completely separate from your Sun Life Grepa position and cannot interfere with your responsibilities and performance as a Sun Life Grepa employee.
Depending on your position at Sun Life Grepa, you may also have a specific regulatory obligation to report outside business activities, certain political contributions and directorships.

Our funds, facilities or services cannot be used for the benefit of other businesses, or political parties and their candidates, except as specifically authorized in advance or as allowed by our Global Government Affairs and Public Policy team. We also have a separate process for dealing with charitable and philanthropic spending. This process requires that all charitable donations go through the donation approval framework which dictates the approval level required for the corresponding funding amounts and requires that all charitable donations are reported.

As employees, Sun Life Grepa respects and is committed to our individual rights to voluntarily participate in the political process for our own personal purposes.

As an organization, we will follow all local laws regarding political activities and campaign financing. As a general practice, we will not make any Corporate financial contributions or donations to any political parties, factions or candidates for public office. However, where permitted by law and authorized by an Executive Vice President or President level officer, we may provide Corporate financial support through Political Action Committees and direct donations. We cannot communicate support or endorse any political candidates, campaigns or causes unless specifically authorized by Sun Life Grepa.

As an employee, we cannot in any way associate Sun Life Grepa or engage in any political activities on Sun Life Grepa’s behalf, including in social media, without prior written authorization. This includes making political donations, communicating political opinions and supporting political candidates, parties or issues. In addition, we cannot use company resources, logos, trademarks, offices, public events or public initiatives for political purposes or seek reimbursement for any political contributions.

Other than information produced and disclosed in the ordinary course of business, all information about Sun Life and its business is confidential and should not be disclosed to anyone outside Sun Life, including family and friends, or to your co-workers unless they need to know the information to carry out their employment. Examples of confidential information may include business plans, product pricing, new product or business initiatives, client lists and merger and acquisition plans. You are expected to keep confidential any information you acquire about Sun Life during your employment, even after you leave the company.

You should not speak for Sun Life, or imply you are doing so, unless you are specifically authorized. Some external communications, such as articles for publication, presentations and remarks made on behalf of Sun Life, may require review and approval prior to release. Consult the law department or marketing and communications for more information.

In addition to everyday communications with outside persons and organizations, you may on occasion be asked to express your views to the media. Please immediately contact the communications representative in your area if the media approach you. As a general rule, Public and Corporate Affairs will respond to questions about Sun Life’s positions on public policy or industry issues.

We are highly visible in many major financial markets and we are committed to complying with the securities laws and regulations in the countries in which we operate and conduct business. When we invest personally or on behalf of our Client accounts, we cannot base our decisions on material information that is not generally available to the public.

Material information is any information that a reasonable investor would consider important in deciding whether to buy, hold or sell the securities of a publicly traded company. There are also certain types of information that can become material over time, such as proposed business transactions. Consult with a member of the Legal team to determine if information is material.

•  Do not trade in Sun Life Grepa securities, or another public company’s securities, no matter how small or large the trade, if this decision is based on material information that is not generally available to the public.
•  Do not “tip” or pass material information on to others, or even share it with co-workers, other than to the Legal or Compliance teams to establish the appropriate ethical walls.

If someone asks you for information about Sun Life Grepa that is not generally available to the public, please direct that inquiry to the Global Government Affairs and Public Policy team, or a member of the Legal team.

Depending on your position at Sun Life Grepa, you may be subject to additional requirements. These can include pre-clearing and reporting on your personal investments, trading public company securities only during specified periods, and filing insider-trading reports.

We all participate in Sun Life Grepa’s internal control framework. Internal controls help us achieve our business objectives, mitigate risks and meet our ethical obligations to our clients and other stakeholders.

Our internal controls are designed to provide reasonable assurance that:

•  Our operations are effective and efficient,
•  Our financial reporting is reliable, and
• We comply with laws and regulations.

Our commitment to internal control is reflected in Sun Life Grepa’s strong control environment, which includes:

• The Sun Life Grepa Audit and Risk Management Committee, which provides oversight and guidance over internal control practices and Sun Life Grepa’s financial reporting,
• A commitment to acting ethically as set out in the Code,
• A sound organizational structure reflecting clear and appropriate accountabilities and authorities, and
•  Competent and appropriately compensated employees.

We are all responsible for Sun Life Grepa’s internal controls and we should understand how they relate to our roles. Working with your People Leader/Manager, you should:

• Clearly understand your department’s objectives and how your role contributes to achieving them.
• Establish and maintain control activities appropriate to achieving your objectives and mitigating associated risks,
• Be aware of changes in your business or business environment affecting your role, and adapt your control activities appropriately, and
• Continually monitor the appropriateness and effectiveness of internal controls for which you are responsible, and resolve related problems on a timely basis.

Be sure to inform your manager and other affected areas when problem occur – regular communication maintains control awareness. If you are unsure how your role is affected by or contributes to internal control you should speak to your manager.

Accurate records and copies of receipts must be submitted with each expense report as we can be reimbursed only for reasonable expenses related to Sun Life Grepa business activities. Ensure expenses are documented and approved in keeping with expense reimbursement standards.

Sun Life Grepa is required to maintain accurate, reliable and complete records to appropriately manage its affairs and comply with legal, regulatory, financial, accounting and operational obligations. The integrity of our records is essential to the successful operation of our business, and to maintaining the trust and confidence of our shareholders, Clients and business partners.

Our financial statements, books and records must accurately reflect all business transactions and be retained in accordance with our record keeping practices. Sun Life Grepa must provide accurate, consistent, informative and timely disclosures of information to the market in accordance with applicable laws. Failing to disclose or record revenues, assets or liabilities is prohibited.

We strictly prohibit employees, subcontractors and their employees, and agents from engaging in or taking any actions that would condone human trafficking or forced and child labour-related activities. These activities include engaging in sex trafficking, procuring commercial sex acts (even if this practice is legal in the jurisdiction where it transpires), using force, fraud, or coercion to subject a person to involuntary servitude, or obtaining labor from a person by threats of serious harm to that person or any other person, among others. If you become aware of any such activities by our colleagues, Clients, suppliers, or anyone else whom we encounter in our work, you must report this immediately to your People Leader, Human Resources, Legal or Compliance representative.

Sun Life Grepa strongly believes in the importance of a culture that values caring and authenticity. More than just being the right thing to do – it’s the key to attracting great talent, supporting an engaged workforce and serving the needs of our Clients and society.

Sun Life Grepa welcomes diversity of all kinds – gender, ethnicity, religion, age, country of origin, sexual orientation, neurodiversity and physical ability. We encourage and support diverse perspectives and beliefs. Sun Life Grepa’s commitment to DE&I includes:

• Supporting a culture where DE&I actions by leaders are expected, and employee differences are celebrated.
• Empowering employees with the tools to understand and apply techniques to address barriers and bias in talent decisions, practices, programs and policies.
• Creating an environment where modeling inclusive behaviors, seeking feedback and embracing diverse perspectives and practices support inclusion.
• Ensuring strong consistent measures for diversity, inclusion and psychological safety are used to track progress and address systemic issues.

We can’t be bystanders and hope that inclusion happens. Through our Code, we support Sun Life Grepa’s DE&I strategy and promote more inclusive business and drive meaningful change. We believe in the importance of an inclusive and caring culture where everybody belongs.

Reflecting our caring and authentic core values, Sun Life Grepa is committed to maintaining a safe, inclusive and respectful work environment, where our well-being is strengthened and we are empowered to bring our best selves to work.

We engage in practices that ensure our work is done safely, with respect to our physical workspace, work processes and use of equipment. Each of us is responsible to report unsafe working conditions, so that appropriate steps can be taken to protect our Clients, ourselves, and each other in the workplace and prevent workplace accidents or injuries.

We do not tolerate acts or threats of violence, intimidation or verbal abuse in our workplace. As well, we do not tolerate harassment, including sexual harassment and bullying, or unlawful discrimination, by or agains anyone in our workplace.

Harassment is a behavior that can cause offence, humiliation, intimidation, embarrasment or distress. You have the right to complain about the behavior of your colleagues (including your leaders), as well as the behavior of third parties, such as Clients or suppliers.

Harassment can take may forms – verbal, written, electronic, visual or physical. Examples include jokes, derogatory, degrading or insulting remarks, gestures or communications, refusal to work or cooperate with others, adverse employment actions based on an employee’s legally protected status, and making a work benefit dependent upon performing sexual favors or threatening retaliatory action for refusal to perform sexual favors.

Unlawful discrimination means treating someone unfairly on the basis of their ethnicity, color, religion, sex, sexual orientation, gender identity, national origin, citizenship, creed, age, marital status, family status, disability or any other ground prohibited by law.

Sun Life Grepa promotes and expects mutual respect at all levels and does not tolerate unlawful discrimination against anyone we encounter in our work.

We are committed to complying with the letter and spirit of anti-bribery and anti-corruption laws in the countries in which we operate. In essence, prohibited activities are defined as offering, giving or accepting anything of value that can improperly influence business decisions or result in obtaining improper business advantages. That’s why:

• We prohibit the direct or indirect use of bribery, kickbacks, payoffs, facilitation payments or other corrupt practices by employees, agents or other parties acting on our behalf.
• We will report suspected and known incidents of bribery and corruption.
• We must maintain accurate books and records.

If you are offered or asked for a bribe, no matter how small, refuse it, clearly state that it is our policy to never accept or offer a bribe, and report it immediately to your local Money Laundering Reporting Officer.

As a global company, upholding human rights is fundamental to being a trusted and responsible business. It’s vital to our ability to make all employees feel safe and ensure they are treated fairly. It helps us mitigate risks in our supply chain and is essential to advancing a more inclusive society.

We strive to align our approach to managing human rights with internationally recognized human rights principles and standards.

We integrate human rights protections in our business – including in our employment practices, products and services, supply chain and investment decision-making processes. Our commitment is supported by policies on employment equity, health and safety, harassment and discriminaiton, and procurement in various regions. These policies help guide our people, as well as suppliers, in respecting human rights and applicable laws.

Sun Life Grepa is committed to protecting the privacy and confidentiality of all personal information about our Clients, employees or other individuals against theft, loss, unauthorized access, disclosure, destruction or misuse. Respecting the privacy of our Clients and employees is critical to maintaining our reputation as a trusted and responsible business and we are guided by Sun Life Grepa’s Client Data Privacy Principles.

We accumulate a great deal of information about our Clients, employees, and others who develop relationships with us. That is why we have an obligation to limit the collection, access, use and disclosure of this information for legitimate business purposes, in accordance with local laws and internal policies.

Respect the principle of need-to-know as we do not access or share confidential Client or employee personal information unless needed to perform our job. We must respect and maintain the confidentiality of our employees’ personal information, such as salaries, performance reviews or disabilities.

Our regulatory requirements and Sun Life Grepa policies related to system access, privacy, security and information management continue to apply when working from home or working remotely. If you become aware of any information security or privacy incidents, contact your local Service Desk and advise your People Leader.

Protecting personal information is everyone’s responsibility.

Sun Life Grepa’s main creditors are its suppliers. At Sun Life Grepa, we want to do business with suppliers that share our values – integrity, engagement, Client focus, excellence, value and innovation – and that can meet our business requirements. Our Strategic Sourcing team identifies and evaluates potential suppliers, then negotiates with and contracts with them to efficiently and cost-effectively procure high-quality goods and services. We assess suppliers on the products and services they offer, as well as their demonstrated ability to meet our business needs.

We expect our suppliers to share our business values and to follow prudent business practices, including business integrity and the responsible treatment of individuals. We engage with suppliers that share our commitment, as outlined in our Code of Business Conduct, to:

• Acting ethically and complying with applicable laws
• Following responsible business practices
• Following responsible employment practices and providing safe working conditions
• Caring for the community and the environment

We are committed to fair and open competition under the highest ethical standards when dealing with our suppliers. These standards – professionalism, honesty and integrity – are reflected in our Code of Conduct.

Sun Life Grepa periodically or when requested submit reports to its creditors on its financial condition through the published Audited Financial Statements and other Certifications issued by any of its duly authorized officers. The provision of the Annual Report or Audited Financial Report ensures the Creditors of the Company’s financial soundness.

Sun Life Grepa also submits to the Securities and Exchange Commission and the Insurance Commission its audited Financial Statements and Annual Statement. As these become public documents once submitted to the regulators, the creditors of the company are also given access to these reports to apprise them of the Financial Condition or status of the Company thereby safeguarding their rights are creditors.

The Company also provides prompt and accurate reports of its financial standing to its creditors. It is the policy of Sun Life to protect the rights of its creditors by maintaining, at all times, the company’s good credit standing. In furtherance thereof, the Company strictly observes contractual obligations, and regard fair and truthful disclosure and transparency of financial records and dealings of utmost importance to assure creditors of the Company’s continued credit worthiness.

Moreover, the Company’s risk based approach to business and adoption of good corporate governance practices further assures the creditors that the company is effectively managing its risks and is committed to sustaining the growth of the Company.

At Sun Life Grepa, we strive to ensure that appropriate policies and procedures are in place to help manage and protect against risks which may threaten our integrity and security, including by way of foreign interference. Some potential sources of security and integrity risks include propaganda and disinformation campaigns, cyber operations, leaks and disclosures and threat to physical security. We all have a right to advocate for our interests openly and transparently; however, covert activity leading to security and integrity risks is prohibited.

Sun Life Grepa supports the use of social media and believes it is an integral part of the way clients interact with us and how we do business.

As an employee of Sun Life Grepa, posting your ideas and opinions on your personal social media account is a great way to express yourself, learn, and build relationships. However, as you are connected with Sun Life Grepa, it is important that you are familiar with the Company’s guidelines for participating in social media, the guiding principles for speaking about Sun Life Grepa, and our commitment to maintaining strong governance and risk management practices.

Think before posting
Always take a moment to consider the potential impact of your posts. The content you publish online leaves a digital footprint and may become accessible to a broader audience than you intended. Be mindful when you post content of a personal nature to any social media site that Clients, advisors, employees, business partners, regulators, and the public could potentially see. Ensure that if you will post Sun Life Grepa-related content, it should be an approved material and is accurate and understand the rules of each social media site before posting content.

Protect Client and confidential information
Unless it is explicitly indicated that it is for public sharing, do not share on social media or public websites any confidential or sensitive information related to our Clients, advisors, employees, business partners, or any Sun Life Grepa information. Sun Life Grepa information includes, but is not limited to, management reports, policies, procedures, or other confidential internal business communication, and all other proprietary materials or non-public available information. When in doubt, speak with your Manager, Human Resources, Marketing, Legal or Compliance.

Seek consent or approval before posting photos, videos or personal information
Before posting photos, videos or personal information of Clients, advisors, employees, and other individuals taken at a Company event, kindly ensure to seek their written consent.

Be mindful of copyrights and trademarks
When sharing content not provided in our website, marketing materials, and social media platforms, be mindful not to post copyrighted or trademarked material without permission. This includes photos, videos, music, and other types of content. Posting an image, material, or an idea owned by someone else may violate intellectual property and other applicable laws. If you refer to materials, views or opinions you’ve seen on another site, credit the source and link to the material rather than copying and pasting.

Don’t make promises or commitments
We must be careful that contents regarding our products and services are consistent with the policy contract or prospectus and are not false, biased, misleading or deceptive. The language and tone used should be clear, appropriate, and correct.

Maintain a respectful and collaborative atmosphere
When posting and engaging with social media content, whether to personal or work-related contacts, maintain a positive and professional tone and always be respectful. When posting about Clients, advisors, employees or business partners, ensure to comply with our policies prohibiting discrimination on the basis of their race, national origin, sex, sexual orientation, gender identity, disability, age, religion, and any other legally protected category. If you are unsure on how to respond to comments about your content on our products and services, consult your Manager, Human Resources, Marketing, Legal or Compliance.

Post content that aligns with your role and own interests
When selecting content, consider content that is relevant to both you and your audience. For example: If you are in a Client-facing role, consider sharing content that demonstrates how Sun Life Grepa’s innovative products and services can help Clients and/or potential Clients with problems that they may be facing.

If you are a Hiring Manager, in addition to posting about the latest open roles on your team, consider also sharing official Sun Life Grepa content that speaks of our workplace culture and our many workplace awards.

Be mindful of the requirements of our Code of Conduct and the Social Media Supplement
Violation of the Code of Conduct and this Social Media Supplement can result in disciplinary action.

Know when and who to reach out
Join us in safeguarding Sun Life Grepa. If you become aware of any material posted on social media or public website that may contain Sun Life Grepa confidential/internal information (e.g., internal training materials, product forms, launch memo, etc.), you may report by scanning the QR Code below.

Questions?
For your questions or comments on social media, don’t hesitate to reach out to your Manager, Human Resources, Marketing, Legal or Compliance.

We are committed to communicating honestly, responsibly and in a manner that demonstrates our values. Only certain authorized individuals can speak for Sun Life Grepa.

Unless you are specifically authorized, do not speak for Sun Life Grepa, or imply you are doing so. In addition to everyday communications with outside persons and organizations, we may occasionally be asked to express our views to the media, if so, immediately contact the communications representative in your area.

In some cases, external communications, such as articles for publication, presentations and remarks made on behalf of Sun Life Grepa, require review and approval prior to release. Always be careful how you communicate to others and the effect it can have on Sun Life Grepa, our reputation and brand. Threatening, discriminatory, hateful or illegal statements – oral, written, in print or via electronic media – will not be tolerated.

The fair treatment of Clients is an integral part of our ethical culture. We are committed to keeping the Client in mind when designing, marketing, distributing and servicing our products and services. We all have a responsibility to consider the Client’s interests in all stages of the product life cycle and to ensure our products and services provide fair value to them.
That is why:

• Our sales will be Client-focused, fair, suitable, and the Clients’ unique needs and circumstances will be considered.
• Our communications will be responsible and professional.
• Our advertising and sales materials, including prospectuses and point of sale materials, will be accurate and clear and will provide full disclosure.
• Our distributors will be competent, ethical and knowledgeable about our products and services and we will monitor their activities.
• Our compensation, commission and incentive structures will be appropriate and encourage fair sales practices.
• Our services will be Client-focused, delivered competently and timely.
•  Client complaints and disputes will be handled promptly, fairly and professionally.

As a general rule, consuming alcohol or substances in the workplace, other than medication for which we have a valid prescription, is not permitted. We may not use alcohol or substances in any way that interferes with the performance of our duties or safety in the workplace. Under no circumstances are we to bring illegal drugs into the workplace. If any of these things occur, we may be sent home and may be subject to disciplinary action, up to and including termination of employment. Note: If our use of prescribed medication or other substances is related to a health condition, and this limits our abilities at work, we should discuss with our People Leader or Human Resources representative.

We are committed to using Sun Life Grepa’s technologies appropriately, as they are important business resources that provide broad access to information and a key aspect to how we conduct business. Our technology includes:

• Information networks, systems and services (such as databases, software, teleconferencing, email, messaging systems, wiki, and internet access); and
• Technology assets (such as computers, mobile devices and portable digital storage media).

Our technology must be used primarily for business purposes. Incidental and appropriate personal use is permitted, provided it does not violate our policies or procedures, and does not interfere with the performance of our job responsibilities. We must safeguard our technology assets and must prevent their damage, loss, theft or misuse. Likewise, we must safeguard the mechanisms and credentials we use to gain access to Sun Life Grepa information and technology.

•  Never download unauthorized applications to your Sun Life Grepa computer.
• Only use approved Sun Life Grepa communication channels and applications to conduct Sun Life Grepa business or transmit Sun Life Grepa information, including on mobile devices. We have an obligation to maintain business records and using only approved communication channels is one way we achieve that.

If Sun Life Grepa becomes involved in litigation or an investigation, all relevant communications or records used or stored within Sun Life Grepa systems or technology assets may have to be turned over to third parties (e.g. law enforcement, regulators, private litigants).

• Keep in mind electronic records are more permanent than you might think – they can be retrieved even after they appear to have been deleted.
• Be careful when using email and other electronic communications, and always avoid making careless, exaggerated or inaccurate statements.

We should have no expectation of privacy when using Sun Life Grepa technology or the files and data stored on Sun Life Grepa technology assets. Sun Life Grepa has access to and may review all files, emails and other electronic communications – business and personal – stored on or transmitted via Sun Life Grepa technologies. Sun Life Grepa monitors the use of all its information networks, systems, services and technology assets including email, chats and storage. In addition, Sun Life Grepa’s data loss prevention efforts are aimed at preventing loss of sensitive data by actively identifying, detecting and protecting sensitive data used within our business operations. Sun Life Grepa will act on any findings that are contrary to our policies and our Code.

If you suspect an information security incident or breach, contact your local Service Desk and advise your People Leader/Manager.

Information and intellectual property are some of our most critical and valuable assets. As employees, we are required to effectively and appropriately manage and protect Sun Life Grepa information and intellectual property under our control.

Sun Life Grepa information includes: all information owned, managed or controlled by Sun Life Grepa or another entity empowered to do so on our behalf, and can include information transmitted over Sun Life Grepa networks or systems. We are expected to keep confidential any information we acquire about Sun Life Grepa and its business activities and operations during our employment except as will be permitted or required by law – even after we leave Sun Life Grepa.

Other than information produced and disclosed in the ordinary course of business, all information about Sun Life Grepa and our business is confidential and cannot be disclosed for unauthorized purposes.

Sun Life Grepa intellectual property includes: our trademarks, logos, copyrighted materials we create on behalf of the organization, audios/videos, slogans and trade secrets, etc. Sun Life is a global company with Clients, employees, advisors, partners and investors all around the world. Maintaining a consistent approach on how we identify our company wherever we do business, is vital. Help protect Sun Life Grepa’s intellectual property by performing your job duties in accordance with Sun Life Grepa’s brand standards.

We are never prohibited from reporting possible violations of law to any regulator or governmental entity, or making other disclosures that are protected under whistle-blower provisions under law, nor are we restricted from discussing the terms and conditions of our employment at Sun Life Grepa.

We must all take reasonable steps to use Sun Life Grepa’s physical assets, including buildings and premises, only for legitimate business purposes and to protect those assets against loss, theft, damage and misuse.

Be careful not to:
– Remove furniture, equipment, supplies or filesand other physical assets or information from Sun Life Grepa premises without authorization. If you are authorized to work at home or off-site, you must keep Sun Life Grepa assets safe and segregated from your personal property.
– Breach any copyright laws or regulations when making copies of documents or software.
– Permit others to use Sun Life Grepa’s assets, without proper authorization.

If you become aware of any loss, theft, damage or misuse of any of Sun Life Grepa’s assets, report it immediately.

Sun Life Grepa is proud to be a hybrid organization that offers the flexibility to work from both the office and virtually based on the needs of the business, our Clients, and our people. This means many roles will have some component of office time which may vary by business and geography, and in how business and Client needs are met. Leaders work with their teams to determine the mix that works best for them. We’re committed to a thriving hybrid workforce and are investing in the tools, resources, training, and spaces to enable and empower our people.