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1. INTRODUCTION 1.1 Whistleblowing is a form of disclosure involving a person, i.e. the whistleblower, who raises serious concerns about the risk of Improper Conduct or to report unethical or unlawful behavior and practices by the Personnel of Sun Life Malaysia Assurance Berhad and Sun Life Malaysia Takaful Berhad (hereinafter collectively referred to as the “Company”) and/or Third Party engaging and having a business relationship with the Company. Whistleblowing at the earliest opportunity may significantly prevent and/or reduce harm arising from Improper Conduct. 1.2 The purpose of the Guidelines 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 The Guidelines shall complement and is to be read in conjunction with all of the Company’s prevailing policies and procedures including policies relating to the prevention of corruption and bribery. 2. SCOPE 2.1 The Guidelines 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 Guidelines. 2.3 All Personnel and Third Party are expected to read, understand and comply with the requirements set in the Guidelines. 3. DEFINITIONS 3.1 The following definitions shall apply in the Guidelines : “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 Guidelines 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 Guidelines; “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 Guidelines; “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 a person that makes a report of Improper Conduct under the Guidelines. 4. IMPROPER CONDUCT 4.1 Improper Conduct is generally any conduct by the Personnel or Third Party (where applicable) 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 following: (a) criminal offence under the law, such as fraud, 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) act of theft and/or involvement in fraud; (d) breach of the Company’s policies, guidelines, applicable Code of Conduct documents and Company’s employment handbook; (e) serious breach of the Company’s confidentiality policies, trade secrets and know how; or (f) 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. 4.3 If a person is unsure whether a particular act or omission constitutes an Improper Conduct under the Guidelines, they are encouraged to contact and seek advice from the Company via email (refer to Appendix A for details) from : (i) BUCO@sunlifemalaysia.com; or (ii) Code@sunlife.com; or (iii) Regles@sunlife.com 5. REQUIREMENT OF GOOD FAITH 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. PROTECTION AGAINST DETRIMENTAL ACTION 6.1 Any Personnel who makes a report of Improper Conduct in good faith (“improper conduct”) 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 termination of appointment or any other retaliatory actions by the Company. 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 Guidelines. 6.4 Any Personnel who makes a report of Improper Conduct and is subsequently subjected to Detrimental Action may lodge a complaint against the individual purported of committing such Detrimental Action via email to : (i) BUCO@sunlifemalaysia.com or (ii) Code@sunlife.com ; or (iii) Regles@sunlife.com. Similarly, a Third Party may lodge a complaint to the Chairman of the Company. 6.5 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. PROTECTION OF CONFIDENTIAL INFORMATION 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, BUCO 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. WHEN PROTECTION MAY NOT BE GIVEN 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: (a) If the report of Improper Conduct is not made in good faith; (b) The report of Improper Conduct is made to intentionally or maliciously destroy the character or reputation of the person reported; (c) The report of the Improper Conduct is made solely or substantially with the motive of avoiding dismissal, termination or other disciplinary action; or (d) The Personnel or Third Party breaches the obligation of confidentiality as stated in the Guidelines. 9. LODGING AN IMPROPER CONDUCT REPORT 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, the Company will assess the report and consider what action may be appropriate. This may involve an informal review, an internal inquiry or a formal investigation. The Whistleblower who lodged the report will be informed by the Company on who is in charge of the investigation and the Whistleblower shall accord full cooperation to the person in charge of the investigation . 10. HOW TO LODGE AN IMPROPER CONDUCT REPORT 10.1 A Personnel who intends to lodge an Improper Conduct report shall first lodge such report (please refer to Appendix A) to their immediate superior or department head. Such report shall be in writing, detailing all evidence or reasons of belief for the making of such report. The Personnel can elect to submit the report anonymously but in order to facilitate a smooth investigation process; it is preferable that the Personnel submit their report with their identity details. A Third Party may lodge an Improper Conduct via written email to the Chairman of the Board - Dato' Noorazman Bin Abd Aziz (noorazman@sunlifemalaysia.com). 10.2 A Personnel or Third Party who submits an Improper Conduct report shall be accorded protection as stated in item 6 and 7 above. 10.3 If there are any reasons which render the Personnel from reporting to their immediate superior or department head, the Personnel may submit the report directly to BUCO via email (BUCO@sunlifemalaysia.com) 10.4 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) go to https://www.employee-ethics-hotline.com/ to submit the Improper Conduct report; or c) Code@sunlife.com; or d) Regles@sunlife.com 10.4 and Third Party may make a disclosure via written email to the Chairman of the Board - Dato' Noorazman Bin Abd Aziz (noorazman@sunlifemalaysia.com). INVESTIGATION PROCESS Upon receiving an Improper Conduct report, the immediate superior/department head/the Chairman of the Board will escalate the report to the BUCO of the Company. The BUCO shall then assess the veracity of such report and conduct the necessary investigations. 11. DECISION 11.1 All findings of the investigation pertaining to Improper Conduct shall be submitted to BUCO to review and decide on disciplinary and corrective action to be taken in line with the relevant Company policies and subject to the laws of Malaysia and/or any other legal obligations. 11.2 Subject to any prohibition in law or any legal obligations, Company will provide relevant updates to the Whistleblower as appropriate. 11.3 All findings pertaining to Improper Conduct shall be kept for recordkeeping purposes or such extended periods as required by the regulatory or any legal authorities. WHISTLEBLOWER PROTECTION ACT 2010 11.4 The Whistleblower Protection Act 2010 (“Act”) accords protection to persons making disclosures of Improper Conduct in the public and private sector from civil and criminal action. In addition, the Act allows for the proper investigation to be carried out by an enforcement agency set up by the federal government such as the Malaysian Anti-Corruption Commission. 11.5 If any Personnel or Third Party wishes to make an Improper Conduct report pursuant to the Act, then the reporting Personnel or the Third Party will have to make the said report to a whistleblowing enforcement agency. Any investigations and/or actions taken thereafter would be in accordance with the Act and are independent of the procedures described in the Guidelines. 11.6 Whilst the Company respects the rights of Personnel to directly make a report of Improper Conduct to an enforcement agency, the Company urges its Personnel to first and foremost report the Improper Conduct internally as per the procedure stated in the Guidelines in order for the Company to remedy any wrongdoings and where applicable, to institute appropriate procedures and control to prevent any serious damage to the Company. 12. REVIEW The Company monitors the effectiveness and reviews the implementation of the Guidelines at appropriate intervals, considering its suitability, adequacy and effectiveness. Any improvements identified are made as soon as possible. Internal control systems and procedures are also subject to regular review to ensure that they are effective. 13. MODIFICATION The Company reserves the right to amend, modify or update the Guidelines periodically and at any time by updating and publishing the effective date of the release of the new version hereof through an internal circulation to the Personnel or by making it available in the Company’s corporate website. 14. QUESTIONS AND FURTHER INFORMATION If you have any questions or require further information about any aspect of the Guidelines, please contact us via email at BUCO@sunlifemalaysia.com.