SUN LIFE FINANCIAL INC

Code of Conduct

We have cultivated a strong organizational foundation grounded in ethical conduct, high business standards, integrity and mutual respect. The Board plays a critical role in setting the "tone from the top," ensuring that Senior Management consistently models and promotes these expectations across the organization.

The Board has established our Code of Conduct (the "Code") to apply to every employee, temporary or contingent worker, and contract staff of Sun Life and its subsidiaries and controlled joint ventures; as well as our Board of Directors. Adherence to the Code is mandatory and a condition of employment and directorship. Annually, everyone is required to complete mandatory Code training and a declaration confirming a commitment to and compliance with the Code.

Our Code encourages transparency and accountability by promoting speaking up and requiring all employees and Board members to report known or suspected breaches. Reports can be made through multiple channels, including our Ethics Hotline, which allows for anonymous submissions. The Ethics Hotline is operated by a third-party service provider who provides the reporting platform, while Sun Life is responsible for the review and investigation of any report submissions. Our Code reinforces our zero-tolerance stance on intimidation and retaliation, and we are firmly committed to protecting individuals who report concerns.

Our Code is also a foundational element of how we conduct ourselves ethically and a key enabler of sustainable success. Through ongoing education, clear communication, and consistent enforcement, it fosters a culture rooted in integrity, transparency, and accountability. The Code is not just a policy - it is a living framework that guides behaviour and decision making across the organization.

The Governance Committee ("GC") of the Board is responsible for overseeing the effectiveness of the Code. This includes monitoring compliance with and reporting of findings to the Board annually. The Chief Compliance Officer provides quarterly updates to the GC, detailing breaches of the Code and review of the effectiveness of related controls and compliance measures. No waivers of the Code have been granted for the members of the Board of Directors or Executive Officers, underscoring our commitment to consistent ethical standards at all levels of leadership.

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The most recent copy of the Code is available on our website (www.sunlife.com). The Code has been filed with the Canadian Securities Administrators ("CSA") in Canada on SEDAR+ (www.sedarplus.ca) and with the Securities and Exchange Commission ("SEC") in the United States on EDGAR (www.sec.gov/EDGAR).