SUN LIFE FINANCIAL INC

The information under the heading “Code of Conduct” in the Company’s 2024 AIF is incorporated by reference herein.

A copy of the current Sun Life Financial Code of Conduct is attached hereto as Exhibit 99.8 and available on our website atwww.sunlife.com under “About Us”.

In 2024, the Company updated its Code of Conduct to reinforce its key principles and values while providing enhanced guidance and clarification to employees and the Board. Key revisions include: a new section on the Company’s culture to clarify expectations and help build awareness of the Company’s values; emphasis on the importance of cooperating with investigations; enhanced content on human rights, sustainability, and diversity, equity & inclusion; clarification on guidelines for appropriate outside activities and employment, including political contributions; the reinforcement of the Company’s requirement to only use approved communication channels and applications to conduct business or transmit Company information, including on mobile devices; and added content on security and integrity, including foreign interference.