Whistleblowing Guideline

1.1 Whistleblowing refers to the confidential act of reporting suspected wrongdoing, misconduct, unethical behaviour, or other activities that are illegal, improper, or contrary to the Company’s Code of Conduct or applicable Company policies. This includes, but is not limited to, violations of laws or regulations, financial fraud, corruption, abuse of authority, threats to public safety, or other misconduct. Whistleblowing allows Personnel or Third Parties, acting in good faith and with reasonable belief of the substance of their concerns, to raise matters involving past, current, or potential future wrongdoing within the workplace.

1.2 The purpose of this Whistleblowing Guideline (“Guideline”) is to outline a formal and confidential way in which the Company’s Personnel and Third Party can express their concerns on any form of Improper Conduct at an early stage and through appropriate channels.

1.3 The Company is committed to ensure that its Personnel and Third Party are able to raise genuine concerns in relation to a breach of a legal obligation, fiduciary duty, and miscarriage of justice, bribery and corruption at the earliest opportunity without being subject to victimization, harassment or discriminatory treatment and to have such concerns properly addressed and investigated.

1.4 This Guideline shall be read in conjunction with the Company’s Code of Conduct and all other applicable policies and procedures, including those relating to the prevention of corruption and bribery.

2.1 This Guideline shall apply to the Company, its Personnel and the Third Party engaging and having a business relationship with the Company.

2.2 Complaint or report of an Improper Conduct against the Company or any of its Personnel can be made by lodging a complaint or report through the appropriate channel set under item 10 of the Guideline.

2.3 All Personnel and Third Party are expected to read, understand and comply with the requirements set in the Guideline.

3.1 The following definitions shall apply in this Guideline:

"BUCO" means Business Unit Compliance Officer of the Company;

"Confidential Information" means any information that is confidential in nature or sensitive and/or not generally available to the public and in the Guideline including but not limited to:

(a) information about the identity, rank, position or other personal details of a Whistleblower;
(b) a person against whom a Whistleblower has made a disclosure;
(c) information disclosed by a Whistleblower; or
(d) information that, if disclosed, may cause detriment to a person.

"Detrimental Action" has the meaning ascribed to it in item 6 of the Guideline;

"Improper Conduct" generally means any conduct by the Personnel which, if proved, constitutes a criminal offence or disciplinary offence, or any conduct that constitutes a wrongdoing or malpractice and may include any of the examples stated in item 4 of the Guideline;

"Personnel" means any person of the Company and shall include permanent employees, fixed term employees, consultants, part-time employees, interns, directors, officers, consultants, advisors and agents and any person acting on behalf of the Company;

"Third Party" means any individual, company, association, partnership, or other entity appointed to act on behalf of or for the benefit of the Company which includes but is not limited to contractors, dealers, distributors, sub-contractors, suppliers, service providers, vendors, intermediaries, joint venture partners, resellers or external fund managers; and

"Whistleblower" means any Personnel or Third Party who, in good faith and with reasonable belief in the substance of their concerns, makes a report of Improper Conduct in accordance with this Guideline.

4.1 Improper Conduct is generally any conduct by the Personnel or Third Party that constitutes wrongdoing, misconduct, unethical behaviour, or activities that may breach laws, regulations, Company policies, or the Company’s Code of Conduct, and may include any of the following:

(a) criminal offence under the law, such as involvement in fraudulent activities, corruption, forgery, cheating, criminal breach of trust, insider trading, abetting or intending to commit criminal offences;
(b) acceptance, involvement or solicitation and offering of a bribe, or a favour in exchange for direct or indirect personal or Company benefits;
(c) abuse of authority including misuse of position or power;
(d) actions or omissions that pose threats to public safety;
(e) breach of the Company’s policies, guidelines, applicable Code of Conduct documents and Company’s employment handbook;
(f) serious breach of the Company’s confidentiality policies, trade secrets and know how; or
(g) failure to comply with provisions of relevant laws and regulations where the Personnel or Third Party knowingly disregards, or does not comply with such provisions.

4.2. An Improper Conduct may occur in the course of the Company’s business or affairs or at any location which is related to the Company’s business. An Improper Conduct may also occur in any activity or event relating to the Company, or in any other events in which the Company is the subject matter.
 

5.1. Since an allegation of Improper Conduct may result in serious personal repercussions for the person that has allegedly committed an Improper Conduct, any person who intends to lodge any report of Improper Conduct (i.e. the Whistleblower) shall ensure that the report of Improper Conduct is made in good faith.

5.2. The element of good faith shall be deemed to be lacking when:
(a) where the person making the report knew or reasonably should have known that the report or any of its contents are false;
(b) where the report is frivolous and vexatious; or
(c) there are any other circumstances that indicate that the report has been made with malicious intent, ulterior motive or for personal gain.

6.1. Subject to item 8 below, any Personnel who makes a report of Improper Conduct in good faith  shall not be subject to unfair dismissal, victimisation, demotion, suspension, intimidation or harassment, discrimination, any action causing injury, loss or damage or any other retaliatory actions, or in other words, a Detrimental Action by the Company.

6.2. Similarly, any Third Party who makes a report of Improper Conduct shall not be subject to any retaliatory actions by the Company subject to item 8 below.

6.3. Any report of Improper Conduct made, even if the report is subsequently found to be untrue shall be eligible for protection under the Guideline.

6.4 Personnel who believe they have been subjected to Detrimental Action after making a report of Improper Conduct should, where appropriate, raise the concern with their immediate superior or department head in the first instance:

If such reporting is not appropriate or feasible (for example, where the superior is involved or the Personnel is uncomfortable raising the matter internally), the Personnel may escalate the concern through any of the reporting channels permitted under the Company’s Code of Conduct, including:

i. their People Leader / Manager;
ii. a member of the local Compliance, Human Resources or Legal team; 
iii. the Sun Life Code Office at Code@sunlife.com; or
iv. submit a report through the Ethics Hotline at www.clearviewconnects.com.

In addition to the Code‑permitted channels above, Personnel may also lodge the complaint directly via email to whistleblowing@sunlifemalaysia.com, which serves as the centralised intake channel for whistleblowing and retaliation‑related complaints in Sun Life Malaysia.

6.5 Similarly, a Third Party may lodge a complaint via email to whistleblowing@sunlifemalaysia.com. A Third Party may also submit a report through the Ethics Hotline at www.clearviewconnects.com.

6.6 Any Personnel who commits a Detrimental Action against any other Personnel who has made a report of Improper Conduct shall be subjected to disciplinary action, which may include termination of employment by the Company.
 

7.1. Any person having knowledge of a report of Improper Conduct should make all reasonable efforts to maintain the confidentiality of the Confidential Information, in particular the identity of the Whistleblower.

7.2. There may be circumstances where it will be necessary to disclose the identity of the Whistleblower for purposes of investigation. If such circumstances arise, the Company will inform the Whistleblower that his/her identity is likely to be disclosed and to obtain his/her consent prior to the said disclosure.

7.3. In order not to jeopardise any investigatory process, the Whistleblower should make all reasonable efforts to maintain the confidentiality of the Confidential Information, in particular, the fact that a report has been lodged, the nature of the Improper Conduct and the identity of the person(s) who have allegedly committed the Improper Conduct.

7.4. Any person in the Company who obtains any Confidential Information in the course of any investigation of an alleged Improper Conduct is not allowed to disclose the Confidential Information or any part thereof.

8.1. A Personnel or a Third Party may not avail himself/herself to the protection against Detrimental Action mentioned at item 6 above in the following circumstances:

1.  If the report of Improper Conduct is not made in good faith;
2. The report of Improper Conduct is made to intentionally or maliciously destroy the character or reputation of the person reported;
3. The report of the Improper Conduct is made solely or substantially with the motive of avoiding dismissal, termination or other disciplinary action; or
4.  The Personnel or Third Party breaches the obligation of confidentiality as stated in the Guideline.

9.1. Any Personnel or Third Party is advised and urged to lodge an Improper Conduct report as soon as he/she discovers that the commission or an intended commission of an Improper Conduct has occurred or in any instance where the Personnel or Third Party is instructed to participate in any Improper Conduct.

9.2. Once the Whistleblower has lodged a report of Improper Conduct, it will be escalated to the appropriate area within the Company to be reviewed lawfully, discreetly, fairly, professionally and in a timely manner. All reports are treated confidentially, and we will do our best to ensure your identity in any follow-up discussions or inquiries will be kept in confidence to the extent appropriate or permitted by law.

10.1. A Third Party may lodge an Improper Conduct via written email to whistleblowing@sunlifemalaysia.com. A Third Party may also submit a report through the Ethics Hotline at www.clearviewconnects.com.

10.2. A Personnel who intends to lodge an Improper Conduct report should, where appropriate, first raise the concern with their immediate superior or department head. The report shall be in writing and include all relevant details or evidence. While a Personnel may elect to submit the report anonymously, providing identity details is encouraged to facilitate a smoother investigation process. If reporting to the immediate superior or department head is not appropriate or feasible (for example, where the superior is involved or the Personnel is uncomfortable raising the matter), the Personnel may escalate the concern through any of the reporting channels permitted under the Company’s Code of Conduct, including:

(a) their People Leader / Manager;
(b) a member of the local Compliance, Human Resources or Legal team; 
(c) the Sun Life Code Office at Code@sunlife.com; or
(d) submitting a report through the Ethics Hotline at www.clearviewconnects.com

In addition to the Code permitted channels above, the Personnel may also lodge the report directly via email to whistleblowing@sunlifemalaysia.com, which serves as the centralised intake channel for whistleblowing matters in Sun Life Malaysia.

10.3. Alternatively, the Personnel may make a disclosure via:

(a) contacting Whistleblowing Ethics Hotline number to speak with a representative by dialing the toll-free numbers at 1-800-81-3463; or
(b) submitting a report through the Ethics Hotline’s web reporting portal at www.clearviewconnects.com.

10.4. The Whistleblower may also lodge an Improper Conduct to enforcement agencies, such as:
(a) Bank Negara Malaysia:
https://www.bnm.gov.my/contact-us

(b) Malaysia Anti-Corruption Commission  https://www.sprm.gov.my/index.php?id=21&page_id=100