2022 ESG Report Introduction ESG at Manulife Environmental Social Governance Corporate Governance Human Rights Risk Management Ethics and Compliance Tax Strategy Data Security and Privacy Executive Compensation Practices Responsible Product Governance Public Policy Performance Data Abbreviations and Acronyms Ethics and Compliance Summary of Our Approach • Our Code of Business Conduct and Ethics affirms the company’s commitment to ethical conduct, complying with all applicable laws, and avoiding conflicts of interest. • All employees and members of our Board of Directors receive training and must certify their compliance with the Code annually. • Employees are encouraged to report compliance concerns to their manager or members of our Compliance, Legal, or Human Resources team. • We also offer a confidential, toll-free Ethics Hotline or online platform, managed by a third-party service provider, for reports of any unprofessional, illegal, or fraudulent matters. Learn more: Ethics and Compliance The Manulife Code of Business Conduct and Ethics (the Code) incorporates the company’s anti-bribery and anti-corruption requirements. The Global Chief Compliance Officer ’s mandate includes responsibility for the Code and the company’s compliance program. The Chief Compliance Officer reports to the Board of Director ’s Audit Committee at least quarterly on the monitoring of compliance matters, including anti-bribery and anti-corruption. Additionally, all employees are responsible for complying with the Code, which includes anti-bribery and anti-corruption requirements. Our employees and all members of Manulife’s Board of Directors received training and must certify their compliance with the Code annually, be well-versed in its provisions, and conduct themselves according to both the letter, and the spirit of those provisions. We also provide training on ethical standards for all employees, including part time employees and contingent workers – where their role is applicable. Failure to comply with the Code can result in disciplinary action up to and including termination of employment. Facilitation payments, a form of bribery and/ or kickback, are considered unfair and unethical business practices that are prohibited by Manulife wherever we do business. This prohibition would apply not only to Manulife employees but also to consultants, vendors, or any third-party conducting business on behalf of Manulife. In addition to other available avenues of reporting, which include speaking with a direct manager, legal, compliance, human resources and employee relations, the Manulife and John Hancock Ethics Hotline is toll-free, available 24-hours per day, seven days per week, and can be used anonymously, if the person so chooses. The confidential Ethics Hotline enables employees to ask questions about the Code or report suspected misconduct and is maintained by a third- party service provider. Unethical, unprofessional, illegal, fraudulent, or other questionable behaviour, including any concern with respect to auditing and accounting matters, may be reported through the confidential Ethics Hotline. Concerns received via the Ethics Hotline related to auditing or accounting matters will be forwarded to Manulife’s Audit Committee by the Global Compliance Chief. In 2022, we made updates to our Ethics Hotline page, streamlining the process to submit a report. Manulife has established a strong system of internal controls globally to ensure a consistent risk assessment of new customers and application of customer due diligence commensurate with the assessment of risk, which at a minimum is a review of government issued IDs and scanning the prospective customer ’s name against the relevant global sanctions watchlists. All Manulife initial and ongoing relationships, including customers, employees, vendors, Board members, etc., are subjected to varying levels of due diligence based on our assessment of risk. Our onboarding and ongoing monitoring of these relationships are consistent with regulatory requirements and our Anti-Money Laundering (AML) and Anti-Terrorist Financing (ATF) policy and guidelines. We have been utilizing well-known AML compliance and customer screening tools, at a company-wide level, to facilitate ongoing customer transaction monitoring and watchlist name scanning. These systems and supporting processes are designed to identify unusual or suspicious customer transactions to enable reviews, due diligence, and accurate and timely reporting to the appropriate regulator(s). Manulife has a comprehensive system of internal controls designed and executed in accordance with our AML/ATF policy and standards to mitigate the risks that our products or services could be used to support any criminal activity or facilitate money laundering. To ensure our key controls are effectively designed and executed, Manulife provides ongoing mandatory company-wide training to our employees and subjects our AML/ ATF controls to ongoing quality assurance testing coupled with independent monitoring and testing from our Second and Third Lines of defense. Photo captured by our colleague: Nguyen Thi Lan, Vietnam 72
