##### 



Exhibit 4




---



##### 



Table of contents
  Mission, Vision and Values
    
    
    2Application of the Code of Business Conduct
    
    
    3Does the Code apply to me?
    
    
    3Annual Code Acknowledgement
    
    
    3How do I apply the Code in my business dealings?
    
    
    4Managers
    
    
    4Other obligations
    
    
    5Other codes/policies
    
    
    5Complying with the law
    
    
    6Fraudulent activities
    
    
    7Anti-money laundering/Anti-terrorist financing
    
    
    8Fairness in the workplace
    
    
    9Avoiding conflicts of interest
    
    
    10Trading in securities
    
    
    11Gifts, favours, benefits or entertainment
    
    
    12Engaging in outside activities or employment
    
    
    13Service on boards
    
    
    14Engaging in political or charitable activity
    
    
    15Personal relationships
    
    
    16
 Dealing with information and assets
    
    
    17Keeping information confidential
    
    
    17Using technology appropriately
    
    
    18-19Using and safeguarding Company assets
    
    
    20Expenses
    
    
    20Personal communications
    
    
    20Maintaining books and records
    
    
    21Maintaining privacy
    
    
    22Dealing with other people and organizations
    
    
    23Acting fairly and professionally
    
    
    23Competing fairly
    
    
    23Communicating with others
    
    
    24General
    
    
    24Continuous disclosure
    
    
    24Media communications
    
    
    24Publications and presentations
    
    
    24Regulatory and other investigations
    
    
    25Audits
    
    
    25Contravention of the Code
    
    
    26What to do if you have contravened the Code.
    
    
    26What to do if you know or suspect that

someone else has contravened the Code
    
    
    26Questions/Policies
    
    
    27-28




---



##### 



Mission, Vision and Values
  Mission
  Vision
  Values
 Integrity
  Engagement
  Customer Focus
  Excellence
  Value
    3
    
    2006 - CODE OF BUSINESS CONDUCT




---



##### 



Application of the Code of Business Conduct
  Does the Code apply to me?
 Annual Code Acknowledgement
  You must read, understand and 
comply with the Code.
    Q.
    
    I have been hired by Sun Life Financial as a temporary employee. Am I required to
complete the Annual Code Acknowledgment?
 A.
    
    Yes. All employees, including temporary employees and contract employees, on Sun Life
Financials payroll system are required to complete the Annual Code Acknowledgement. This
process confirms that you have complied with the Code while you have been employed by Sun Life
Financial and reaffirms your commitment to do so for the remainder of
your contract.
 Q.
    
    Where can I find a copy of the Annual CodeAcknowledgement form and how do I complete it?A.
    
    You will receive the Annual Code Acknowledgement form in early December, and it must be
completed by early January. Most employees will complete the form online but if you do not
have computer access, a hard copy will be provided. Employees on leave will be asked to
complete the Annual Code Acknowledgement when they return to work. Every employee must
complete the Annual Code Acknowledgement.
 2006 - CODE OF BUSINESS CONDUCT
    
    4




---



##### 



How do I apply the Code in my business dealings?
 If you encounter a situation for which the Code does not provide specific guidance, ask
yourself the following questions:
 
    
    Is this fair and ethical?
 
    
    Is this legal?
 
    
    Am I confident that Sun Life Financial would not be embarrassed if this situation
became public knowledge?
 
    
    Would I approve of this situation if I were
a fellow employee, a customer or a shareholder?
  Apply the Code to situations 
you encounter at work.
 Managers
 If you are a manager you should:
 
    
    Act ethically and foster a work environment that reflects the content and the spirit of the Code;
 
    
    Train employees to act ethically in all dealings;
 
    
    Understand the Code and champion it with your team members;
 
    
    Answer employee questions about the Code or direct them to where they can find the information they need;
 
    
    Take steps to prevent breaches of the Code and to report and respond to any violations;
 
    
    Support and protect those who report breaches; and
 
    
    Report any breaches or potential breaches of the Code to your local compliance officer.
 Managers, by virtue of their 
positions of authority, must act 
as ethical role models
for others.
    Q.
    
    Where can I obtain more information about the Code and how to apply it?A.
    
    If you are unsure how to apply the Code in any situation:
 1.
    
    Discuss the matter with your manager or a representative in Compliance, Human Resources,
Law or Public and Corporate Affairs identified in the Contact Lists.2.
    
    Review additional information about the Sun Life Financial Code of Business Conduct site on The Source (if you have access to the
Company intranet).3.
    
    E-mail: SLF_Code_of_Business_Conduct@sunlife.com.
 Q.
    
    My manager asked me to do something that I think may violate the Code. Im not comfortable
talking to him about it. How should I go about reporting this?A.
    
    Contact your local compliance officer who can discuss the Code with you and address your
concerns about the possible breach. If this does not resolve the situation contact the person
in the Law Department primarily responsible for advising your business unit or function, or
make a report using the Employee Ethics Hotline.
 5
    
    2006 - CODE OF BUSINESS CONDUCT




---



##### 



Other obligations
  As a result of your specific position within Sun Life Financial or your professional
background, you may be required to comply with other obligations, such as:
 
    
    Supplementary codes of business conduct or guidelines relating to specific activities,
companies or business units within Sun Life Financial;
 
    
    Rules of conduct governing members of your professional group or association; and
 
    
    Sun Life Financial policies governing specific situations you may encounter in your
work.
 Other codes/policies
 If you have any questions about 
whether a supplementary code of 
business conduct or policy applies
to you, please talk to your manager.
   2006 - CODE OF BUSINESS CONDUCT
    
    6




---



##### 



Complying with the law
  Acting ethically requires you to
comply with the laws, rules, and
regulations applicable to your job
and to work to the spirit of the
law.
     Q.
    
    I work in an area of Sun Life Financial where many different laws apply to the work I
do. How can I be sure that I wont violate some technical aspect of one of these laws?
 A.
    
    Use your common sense and always ask questions when you are unsure. You need to make every
effort to understand and follow the laws governing your job. The person in the Law Department
primarily responsible for advising your business unit or function will be familiar with the laws
applicable to your work. Do not hesitate to contact him or her or your manager if you need
clarification.
 7
    
    2006 - CODE OF BUSINESS CONDUCT




---



##### 



Fraudulent activities
  Report any suspected fraud 
immediately.
 A fraudulent act is any dishonest act intended to deprive or mislead for personal or corporate
gain. Examples of fraudulent acts and omissions include, but are not limited to:
 
    
    Forging or altering any document including a cheque, bank draft, or other financial
instrument, or account belonging to Sun Life Financial or its customers;
 
    
    Improperly handling or reporting money or financial transactions;
 
    
    Deliberately misleading customers with the intention of depriving them of money or other
assets;
 
    
    Intentionally misrepresenting financial accounts or reports, or failing to disclose such
misrepresentations;
 
    
    Identity theft-deliberately misusing (directly or indirectly) a customers or employees
personal information for any purpose including depriving him or her of money or other assets;
and
 
    
    Any fraud, material or not, that involves management or other employees who have significant
roles in Sun Life Financials internal controls.
    Q.
    
    I am concerned that my colleague may be committing fraud against Sun Life Financial,
but I am not really sure. What should I do?
 A.
    
    Call your local Fraud Reporting Officer as required by the Sun Life Financial Fraud Reporting
and Investigation Policy to report your concern. All information will be handled discreetly
during the investigation to the extent permitted by policy or law. If we can find no independent
corroboration of your concern, no action will be taken against your colleague. No action will be
taken against you for your report. Even if your colleague suspects that you have reported him or
her, Sun Life Financial strictly prohibits any form of retaliation against you for reporting your
concern in good faith.
 2006 - CODE OF BUSINESS CONDUCT
    
    8




---



##### 



Anti-money laundering/Anti-terrorist financing
  You must actively protect 
Sun Life Financials products and 
services from being used for money 
laundering or for financing terrorist 
or other criminal activity.
 
    Q.
    
    What are some signs of money laundering?A.
    
    Pay close attention to customer transaction requests or behaviour that seems out of the
ordinary, such as:
 
    
    admissions or statements about involvement in criminal activities;
    
    reluctance to have information sent to a home address;
    
    repeatedly using an address but frequently changing the name attached to it;
    
    keen interest in internal systems, controls and policies;
    
    providing inconsistent information about a transaction;
    
    greater interest in liquidity than other features of a product;
 
    
    giving an incorrect telephone number or disconnecting their telephone service just after
a transaction;
    
    the use of aliases and a variety of similar but different addresses;
    
    reluctance to present proper ID for identity verification;
    
    refusing to disclose beneficial owners; and
    
    offers of money for providing services that appear unusual or suspicious.
 9
    
    2006 - CODE OF BUSINESS CONDUCT




---



##### 



Fairness in the workplace
  
 You must treat your co-workers, 
customers and others with respect 
and dignity.
    Q.
    
    Im looking to fill a senior position on my team from a pool of qualified
candidates. May I offer the job to a man instead of a woman if l believe the woman is likely
to start a family soon?A.
    
    No, this would be a violation of Sun Life Financials policy. All employment-related decisions
must be based on job-related criteria, skills, and performance. Contact your local Human
Resources Department for more information, or check local human resources policies.Q.
    
    My teammates sometimes tease me about my
national origin. I dont think they mean any harm by it. Should I report them?A.
    
    Yes. This behaviour violates the Code. You can advise the employees that their comments are
not acceptable if you feel comfortable doing so. You should also promptly report this to your
manager, to your local Human Resources Department or to the Law Department. A report can also
be made using the Sun Life Financial Employee Ethics Hotline.
 Q.
    
    I witnessed my teammate being threatened by another Sun Life Financial employee. They were
scared and did not want to report the incident. Do I need to report this?A.
    
    Yes. Report the situation to your manager. If you are uncomfortable doing this, call your
local Human Resources Department or submit a report to the Employee Ethics Hotline. Sun Life
Financial investigates all reported acts of threats or violence.
 2006 - CODE OF BUSINESS CONDUCT
    
    10




---



##### 



Avoiding conflicts of interest
  You must avoid any conflict or
appearance of conflict between
your personal interests and
those 
of Sun Life Financial.
     Q.
    
    May I hire my brother to do some contract work for Sun Life Financial if his rates
are the best rates available?A.
    
    No. Sun Life Financial generally prohibits business dealings with employees family members.
Regardless of your brothers rates, Sun Life Financial will not hire him to perform services
under a contract if he will be working under your supervision or if you have any influence
over the decision to employ him.
 Q.
    
    My husband has just become an executive sales manager for a company that services the
computers in my department. Do I need to tell anyone about this?A.
    
    Yes. One of your husbands competitors or a fellow Sun Life Financial employee could claim
that your husband is getting Sun Life Financials business because you are a Sun Life
Financial employee. You should ensure that you are independent, and are seen to be
independent, from any business organization that has a contractual relationship to provide
goods or services to Sun Life Financial. You should notify your manager and make sure you are
not involved in any decisions regarding your husbands company.
 11
    
    2006 - CODE OF BUSINESS CONDUCT




---



##### 



Trading in securities
  
 You must not buy or sell securities 
of Sun Life Financial or another 
publicly traded
company if you 
possess material non-public 
information. In many countries, 
trading or
tipping someone else who 
trades based on this information 
also violates securities laws.
    Q.
    
    I overheard in the elevator that Sun Life Financial is planning to acquire XYZ, a
large public company. May I trade in the securities of the other company?
 A.
    
    No, and you also must not trade in the securities of Sun Life Financial. The prohibition on
trading is not affected by the manner in which you obtained details. Please refer to the
Insider Trading Policy for information.
 Q.
    
    I am part of a team that supports the release of our quarterly financial results. In the days
leading up to the release of the results, I see draft documents discussing the results before
they are approved for release. Is it okay for me to discuss this information in general with
people outside of Sun Life Financial if I dont refer to specific financial numbers?
 A.
    
    No. This information is not yet public and should be treated as confidential proprietary Sun
Life Financial information. In addition, if you disclose any material information you may be
breaking securities laws.
 2006 - CODE OF BUSINESS CONDUCT
    
    12




---



##### 



Gifts, favours, benefits or entertainment
  
    
    the value involved is nominal (check for local policies or speak to your manager for guidance
on what constitutes nominal in your Business Group as this can vary);
 
    
    it occurs infrequently;
 
    
    the exchange creates no sense of obligation on either party; and
 
    
    it would not embarrass Sun Life Financial or the recipient, if publicly disclosed.
 Talk to your manager if you are 
unsure about accepting or giving gifts, 
favours,
benefits or entertainment.
 
    Q.
    
    I work in strategic sourcing at Sun Life Financial. I recently received a call from a
potential supplier offering me the use of his luxury condominium. He indicated that it would
not be in use at the time and that it would be a shame to have it empty. Should I accept the
invitation?
 A.
    
    No. The suppliers offer is too generous. You should decline the offer because it may
influence your decision as to whether to grant an order to the supplier or, at the very least,
it could appear to influence your decision.
 Q.
    
    Im a communications consultant in a business unit and Ive been hiring outside graphic design
firms to assist me with projects. These firms usually send me a bottle of wine when a big project
wraps up. I believe its a fairly common practice. Am I allowed to accept it?
 A.
    
    Yes. The gift is provided infrequently and the value is nominal. If however there were
several gifts from the same firm you would need to consider if a conflict of interest exists.
Speak to your manager if you have any questions.
 13
    
    2006 - CODE OF BUSINESS CONDUCT




---



##### 



Engaging in outside activities or employment
  
 You must not serve another 
organization if there is or appears 
to be a conflict of interest
with 
Sun Life Financial or if the demands 
interfere with your responsibilities 
at Sun Life
Financial.
    Q.
    
    May I work for another company if the hours dont conflict with when Im required to
work at Sun Life Financial?
 A.
    
    That depends. You may not take on another job that creates a conflict of interest with your
position at Sun Life Financial. A second job must be kept completely separate from your
position at Sun Life Financial and must not interfere with your responsibilities and
performance as a Sun Life Financial employee.
 Q.
    
    May I accept an appointment to the board of directors of a company that occasionally supplies
services to Sun Life Financial business units?
 A.
    
    You must consult the person in the Law Department primarily responsible for advising your
business unit or function to determine whether a conflict of interest exists. If you do join
the other companys board, you are obligated to protect Sun Life Financials confidential
information and must not vote on any board issues related to doing business with Sun Life
Financial.
 2006 - CODE OF BUSINESS CONDUCT
    
    14




---



##### 



Service on boards
  Serving as a director for other 
companies, government agencies,
 and organizations may
create a 
conflict of interest.
 
   13
    
    2006 - CODE OF BUSINESS CONDUCT




---



##### 



Engaging
in political or charitable activity
   You
need to consult with Public 
and Corporate Affairs before using 
Sun
Life Financial assets for 
political or charitable purposes.
    Q.
    
    A friend of mine is running for office. May I take time off to assist her political
campaign?A.
    
    Yes, as long as arrangements are made to meet business needs in your absence. You may use
vacation time or unpaid absence days to support political activities. Assisting in a political
campaign does not qualify as a paid absence. For more information speak with your manager or
your local Human Resources Department.
 Q.
    
    I volunteer for a local charity. May I use my
Sun Life Financial computer to send out a monthly e-newsletter to supporters of the charity?
 A.
    
    Its great that you are getting involved in community activities but you need to consult with
Public and Corporate Affairs before using Sun Life Financial assets for political or
charitable purposes.
 2006 - CODE OF BUSINESS CONDUCT
    
    16




---



##### 



Personal relationships
   A relative is defined as:
 
    
    parent (natural or in-law);
    
    spouse (legal, common-law or other
domestic partner);
    
    son or daughter (natural, step children or in-laws);
    
    brother or sister (natural, step or in-law); or
    
    other close personal relationship if it is deemed
that the relationship may impede proper business
practices and objective decision making.
 Talk to
your manager before you
hire or engage a family member or
their business to provide goods or
services to Sun Life Financial to
ensure there is no conflict.
    Q.
    
    I work in one of the accounting departments of Sun Life Financial. I have an
accounting project that my son, who has just completed his accounting certificate, could
easily complete. May I hire him under my supervision?
 A.
    
    No. Although your son may be qualified for the position, hiring him would be a conflict of
interest if he will be working under your supervision or if you have any influence over the
decision to employ him. Consult the Employment of Relatives Policy or contact your local Human
Resources Department for more information.
 17
    
    2006 - CODE OF BUSINESS CONDUCT




---



##### 



Dealing with information and assets
 Keeping information confidential
     You are responsible for
protecting
confidential information
against
theft, loss, unauthorized
access,
disclosure, destruction or
misuse.
    Q.
    
    Sun Life Financial recently hired an executive from another financial services
company. In his role at our competitor he had access to important confidential and proprietary
information that would be quite helpful. May we ask him to share this information?
 A.
    
    No. The new employee has an obligation to protect his former companys confidential and
proprietary information just as you would be expected to protect the confidential information
of Sun Life Financial if you were to leave the Company.
 Q.
    
    Are there certain issues I need to be careful about discussing in trade association and
industry meetings?
 A.
    
    Trade association members are also our competitors. If you are appointed to represent Sun
Life Financial in a trade association or other organization, your contributions must respect
the confidentiality of Sun Life Financials information. Consult with the person in the Law
Department primarily responsible for advising your business unit or function, or Public and
Corporate Affairs for more information.
 2006 - CODE OF BUSINESS CONDUCT
    
    18




---



##### 



Using technology appropriately
 You should use the Internet, 
intranets, and telephones primarily 
for business purposes while
you 
are at work. Incidental appropriate 
personal use is allowed as
long 
as it does not interfere
with your 
business responsibilities.
     Q.
    
    I occasionally receive humorous e-mails at my Sun Life Financial address. They are
sent to me by people outside the Company without my consent. Some of them could be offensive
and I worry I may have I breached the Code simply by reading the e-mail?
 A.
    
    No, but you should ask these people not to send you any more of these e-mails. It is not
appropriate for you to receive or send jokes that are potentially offensive to others. You
need to be aware that e-mail is not private and may be monitored. E-mail is stored on Sun Life
Financial servers and networks. You are responsible for taking reasonable steps to ensure that
the e-mails you send and receive do not violate the Internet/E-communication Access and Use
Policy.
 Q.
    
    My friend gave me software that would be very helpful to me in preparing a presentation for an
upcoming sales conference. Am I allowed to install it on my Sun Life Financial computer?
 A.
    
    No. It is inappropriate to download or exchange any type of software on Sun Life Financials
equipment. Consult the Internet/E-communication Access and Use Policy for more information.
 19
    
    2006 - CODE OF BUSINESS CONDUCT




---



##### 



Using technology appropriately (contd)
 When using Sun Life Financial electronic communications systems:
 
    
    Be careful when using e-mail and avoid careless,
exaggerated or inaccurate e-mail statements that
could be misunderstood or used against you or
Sun Life Financial in a legal proceeding. Remember  if Sun Life Financial becomes involved in litigation or
an investigation, your e-mails may have to be turned
over to third parties. E-mail can be retrieved even
after you have deleted it from your in-box. Before
you hit send, reread.
    
    You must have the permission of your IT department
or manager to use Instant Messaging (IM) at work.
 
    
    Accessing, downloading and distributing obscene
and offensive material of any kind is prohibited.
    
    Do not compromise our network security by either
installing or using peer-to-peer (P2P) or other similar
types of file sharing applications that allow you to
download music, video clips and/or image files.
    
    Do not share your computer user IDs and passwords.
You will be responsible for inappropriate activity
taken on accounts or equipment where confidential
password access is required.
     Q.
    
    Is it okay for me to download music from the Internet to my Sun Life Financial computer.A.
    
    No, this is not appropriate for many reasons. Copyrightable material must not be downloaded
without the consent of the materials owner or publisher. Also, this could expose our network
to viruses.
 Q.
    
    In addition to my job at Sun Life Financial Ive been running my own web-based business. Is it
okay for me to use my Sun Life Financial laptop and Internet access to check on my business from
home when Im not required to be working for Sun Life Financial?A.
    
    No. You must not use Sun Life Financials equipment and resources for your own business. The
Internet/ E-communication Access and Use Policy permits only incidental personal use provided
it does not interfere with your business responsibilities, and provided it complies with all
rules set out in this Code and other applicable Sun Life Financial policies.
 2006 - CODE OF BUSINESS CONDUCT
    
    20




---



##### 



Using and safeguarding Company assets
   You must be careful not to:
 
    
    breach any copyright laws or regulations when making copies of documents or software;
    
    reveal Sun Life Financial confidential information; and
    
    permit others to use Sun Life Financials assets, such
as its trademarks, without appropriate consent.
  You may
only use Sun Life Financials
assets for legitimate business
purposes, and
are required to use
good judgment in spending
Company funds.
 Expenses
  Personal communications
   21
    
    2006 - CODE OF BUSINESS CONDUCT




---



##### 



Maintaining books and records
    You
must ensure that your
accounting and financial records
meet the highest standards.
     Q.
    
    The records retention procedure in my area provides that certain types of documents
need to be retained only for a set number of years. How do these procedures apply if a
document might be relevant to a suspected violation of law or an investigation?A.
    
    If a violation of law is suspected or an investigation is imminent, you must retain all
documents relating to the suspected violation or investigation. For more information consult
the records retention procedure adopted by your business unit or consult the person in the Law
Department primarily responsible for advising your business unit or function.
 Q.
    
    I regularly clean out my e-mail inbox. Are there any rules as to what messages should be kept
and which ones should be deleted?A.
    
    The E-mail Retention Policy provides retention information for e-mail and attachments. You
can also check your local records retention procedure for more information.
 2006 - CODE OF BUSINESS CONDUCT
    
    22




---



##### 

\

Maintaining privacy
 You
must protect personal
information about Sun Life Financial
customers and employees.
     Q.
    
    You are a call centre employee and receive a call from someone asking whether their
former spouse (our client) has removed him or her as the beneficiary of their former spouses
policy. Should you answer his or her questions?
 A.
    
    No. All policyholder, customer and employee information is to be kept confidential. Our client
is the policyholder not the beneficiary, and it is only the policyholder who can grant permission
to share his or her confidential information.
 23
    
    2006 - CODE OF BUSINESS CONDUCT




---



##### 



Dealing with other people and organizations
  Acting fairly and professionally
   Act
fairly and professionally 
when dealing with our customers, 
suppliers and competitors.
 Competing fairly
   
    
    pricing;
    
    product and service development; or
    
    customer lists.
     Q.
    
    What are acceptable methods to obtain information about our competitors?A.
    
    Information obtained about competitors must be publicly available information such as annual
reports, expert analyses, press releases, the Internet, trade journals, and so on.
 Q.
    
    At a recent meeting of industry professionals an attendee representing another company asked
me if there would be any interest on the part of Sun Life Financial in entering into a secret
agreement not to compete against each other in certain markets. He explained this would put a lot
of pressure on a mutual competitor of ours. I told him it didnt sound ethical to me and avoided
conversations with him for the rest of the event. Do I need to report this to someone?A.
    
    Yes. The proposal was in violation of competition law and you must report it to the person in
the Law Department primarily responsible for advising your business unit or function.
 2006 - CODE OF BUSINESS CONDUCT
    
    24




---



##### 



Communicating with others
 General
  You should not speak for
Sun Life Financial unless you have
been expressly authorized to do so.

Continuous disclosure
 Media communications
   Publications and presentations
  Refer media questions to the 
media relations representative 
in your area. Consult
the Disclosure 
Policy and Media Guidelines for 
more information.
    Q.
    
    What should I do if I get a call from the media asking me for information about a
proposed acquisition that Sun Life Financial announced through a press release? Is it okay for
me to comment since the news is public?
 A.
    
    No. You should refer the call to the media relations representative in your area. Even though
Sun Life Financial has made a public announcement about a development or transaction, you should
not comment If you have any other questions refer to the Disclosure Policy and Media Guidelines.
 25
    
    2006 - CODE OF BUSINESS CONDUCT




---



##### 



Regulatory and other investigations
 Audits
  When
you are being audited, you must not:
 
    
    directly or indirectly provide misleading
information to the auditor;
    
    withhold any relevant information;
    
    bribe the auditor in any way; or
    
    provide an inaccurate legal analysis or
business rationale.
   2006 - CODE OF BUSINESS CONDUCT
    
    26




---



##### 



Contravention of the Code
  What to do if you have contravened the Code
  What to do if you know or suspect that someone else has contravened the Code
  
    
    any breach or suspected breach of the Code,
supplemental code of business conduct or any
Sun Life Financial policy;
    
    concerns regarding any questionable accounting
or auditing matter;
    
    situations in which you feel you are being pressured
to violate the law or your ethical responsibilities; or
    
    any other breaches of business ethics or legal or
regulatory requirements.
 
    Q.
    
    Can my employment really be terminated for violating the Code?A.
    
    Yes. Your employment may be terminated regardless of your position. Disciplinary action, up
to and including termination of employment, may occur for any deviation from this Code or from
any of Sun Life Financials other policies.Q.
    
    What happens when I use the Employee Ethics Hotline?A.
    
    If you use the Employee Ethics Hotline:
 
    Specially trained employees from an external service provider will create a report based
on your call or website submission and create a confidential report. You do not need to give
your name if youd rather be anonymous.
 
    
    You will be asked to identify what country youre
reporting from so the report can be forwarded to
your local compliance officer for investigation.
(Theres no direct contact between you and the
compliance officer as the Employee Ethics Hotline
acts as an intermediary.)
    
    A senior compliance officer will complete a
follow-up report. You will be provided with a report
number by the service provider so that you can call
or check back online for a status update or to add
more details to your report at a later date.
 Note:
 27
    
    2006 - CODE OF BUSINESS CONDUCT




---



##### 



Questions
/ Policies
  
    
    talk to your manager;
    
    contact anybody identified in the Contact Lists; or
    
    send an e-mail to
SLF_Code_of_Business_Conduct@sunlife.com.
 
   Issue
    
    
    Page
    
    
    Relevant Policy/ContactsAnti-money laundering/Anti-terrorist 
financing
    
    
    
    8
    
    
    
    Global Anti-Money Laundering Policy and Global
Suppression of Terrorism Policy, local anti-money
laundering policies and your local Money Laundering
Reporting OfficerBooks and records
    
    
    
    21
    
    
    
    Sun Life Financial Fraud Reporting and Investigation
Policy and local retention of records policiesCommunications
    
    
    
    24
    
    
    
    Media Guidelines and Disclosure PolicyCompany assets
    
    
    
    20
    
    
    
    Information Security PolicyCompeting fairly
    
    
    
    23
    
    
    
    Market Conduct PolicyComplying with the law
    
    
    
    6
    
    
    
    The person in the Law Department primarily
responsible for advising your business unit or function and
the Sun Life Financial Legislative Compliance Management
PolicyConfidential information
    
    
    
    17
    
    
    
    Information Security Policy and Disclosure PolicyContravention of the Code
    
    
    
    26
    
    
    
    Local Compliance Officer, Chief Compliance Officer,
Employee Ethics Hotline, SLF_Code_of_Business Conduct@sunlife.comBoard of Directorships
    
    
    
    14
    
    
    
    The person in the Law Department primarily
responsible for advising your business unit or
functionDisclosure
    
    
    
    24/25
    
    
    
    Disclosure Policy, Sun Life Financial Insider Trading
Policy, and the Internet/ E-communication Access and Use
PolicyExpenses
    
    
    
    20/21
    
    
    
    Employee Reimbursement Policy, the North American
Travel and Conference Policy or your local travel
policyFairness in the workplace
    
    
    
    9
    
    
    
    Local human resources policiesFraud
    
    
    
    7
    
    
    
    Sun Life Financial Fraud Reporting and Investigation
Policy and your local Fraud Reporting Officer
 2006 - CODE OF BUSINESS CONDUCT
    
    28




---



##### 



Issue
    
    
    Page
    
    
    Relevant Policy/ContactsGifts
    
    
    
    12
    
    
    
    Local human resources policiesMedia communications
    
    
    
    24
    
    
    
    Media Guidelines and Disclosure PolicyOutside activities or
employment
    
    
    
    13
    
    
    

A
Human Resources Director or the person in the Law Department
primarily responsible for advising your business unit or functionPersonal Relationships
    
    
    
    16
    
    
    
    Employment of Relatives Policy and local human resources policiesPrivacy
    
    
    
    22
    
    
    
    The Global Privacy Commitment, local privacy policies, Disclosure
Policy, Internet/E-communication Access and Use Policy and Information
Security Policy or your local Privacy OfficerRegulatory investigations
    
    
    
    25
    
    
    
    Local compliance officer or the person in the Law Department
primarily responsible for advising your business unit or functionSecurities trading
    
    
    
    11
    
    
    
    Sun Life Financial Insider Trading Policy and contact the person in
the Law Department primarily responsible for advising your business unit
or functionTechnology
    
    
    
    18/19
    
    
    
    Information Security Policy and the Internet/E-communication Access
and Use Policy
  29
    
    2006 - CODE OF BUSINESS CONDUCT