Our sustainability governance framework is designed to help us achieve our sustainability objectives across our global franchise, facilitating easier and more strategic decision-making within the context of our business goals.
Oversight of our sustainability framework is part of the mandate of our Board of Directors’ Corporate Governance and Nominating Committee (CGNC). The CGNC reviews the progress made on our sustainability strategy and stays informed of trends, risks, and opportunities through management engagement and reporting at each meeting. As of February 28, 2025 the CGNC includes the Chair of the Board and six other independent Board members.
Experience in and an understanding of sustainability matters are considered essential characteristics for Directors because of the Board's role in overseeing Manulife's ESG framework. Environmental, climate and social experience was added as a key experience to the Board’s skills matrix in 2023, to denote those directors who have a significant knowledge and understanding of relevant issues based on their respective experiences in their professional careers or as a corporate director.
Board members gain sustainability experience through ongoing education sessions and reports on ESG strategy, trends, risks, and opportunities and are encouraged to attend sessions on ESG matters at meetings of the CGNC. In addition to these regular internal sessions, members of the CGNC participate in at least one externally facilitated sustainability-related education session every two years. The sessions may be external courses or externally facilitated sessions tailored to cover issues relevant to Manulife and open to all Board members. In 2024, the Board engaged an external facilitator to provide an educational session on climate transition planning & transition finance.
The CGNC’s oversight of our sustainability framework complements the work of the Executive Sustainability Council (ESC). The ESC consists of our Global Chief Sustainability Officer (CSO) and eleven members of our Executive Leadership Team (ELT), including our Chief Executive Officer (CEO). The ESC is scheduled to meet monthly and is responsible for establishing the enterprise’s sustainability ambition, guiding the development and execution of the sustainability strategy, and providing recommendations and direction on matters related to ESG. In addition to the ESC, within our asset management business we have business segment level committees that execute asset-class-specific sustainability objectives.
The CSO chairs Manulife’s Sustainability Centre of Expertise (CoE), which consists of corporate function and business unit leads tasked with integrating sustainability into our business practices. This group’s responsibilities include leading the development and implementation of the sustainability strategy. Additionally, the CoE ensures integration of sustainability into business unit strategies, policies, and procedures. The CoE shares information, builds knowledge across functions and business units, advises on sustainability matters, and provides support and capacity building to business units.
Partnership and Engagements
Manulife is a Member of Several Global Sustainability Networks
To continue our work to protect and preserve the environment, support health and well-being, and drive inclusive economic opportunity in the communities where we live and work, we collaborate with a number of sustainability-focused organizations. Our strategy is to work together with those from diverse backgrounds and in different industries to learn, upskill, contribute and build capacity.
The Canadian Sustainability Standards Board. Manulife Investment Management is a member of The Canadian Sustainability Standards Board (CSSB) which works with the International Sustainability Standards Board (ISSB) to support the uptake of ISSB standards in Canada, highlight key issues for the Canadian context, and facilitate interoperability between ISSB standards and any forthcoming CSSB standards.
Climate Action 100+. In 2017, Manulife Investment Management became a founding member of Climate Action 100+.
ESG Data Convergence Initiative. Manulife Investment Management supports and participates in this initiative, and we have aligned our annual reporting to this initiative for our Private Equity and Credit, and Infrastructure businesses.
Finance for Biodiversity Foundation. Manulife Wealth and Asset Management is a member and participates in working groups where we contribute to engagement and target setting frameworks on nature.
The International Sustainability Standards Board. Manulife has been a member of the ISSB Investor Advisory Group since 2019. We continue to monitor the evolution of the standards and we may evolve our reporting as new standards materialize.
Principles for Responsible Investment (PRI). Manulife Investment Management has been a signatory since 2015 and is an active member of various working groups, including the Infrastructure Advisory Committee, Listed Equity Advisory Committee, Stewardship Initiative on Nature Signatory Advisory Committee, and Real Estate Advisory Committee. Our annual submission to the PRI reports on Manulife Investment Management’s activities and progress in implementing the PRI’s principles according to the PRI’s reporting framework.
Stakeholder Capitalism Metrics Initiative. Led by the World Economic Forum (WEF), the Stakeholder Capitalism Metrics initiative promotes alignment among existing ESG frameworks and establishes a set of metrics that enhances comparability and consistency.
Task Force on Climate-related Financial Disclosures (TCFD). Manulife has been a supporter of the Task Force on Climate-related Financial Disclosures (TCFD) since 2017 and is committed to adopting and aligning our disclosures to the TCFD recommendations, now overseen by the International Financial Reporting Standards Foundation's ISSB.
Task Force for Nature Related Financial Disclosures (TNFD). Manulife has been involved in key industry groups shaping this key disclosure framework.
United Nations Global Compact. In 2022, Manulife became a signatory of the UN Global Compact, a non-binding United Nations pact to encourage businesses and firms worldwide to adopt sustainable and socially responsible policies and to report on the implementation.
World Business Council for Sustainable Development. Manulife Investment Management has been a member since 2019.
Sustainability Policies and Position Statements
The following are our Sustainability related policies and position statements that guide our work:
Manulife will not knowingly make direct investments in companies that manufacture cluster munitions where we have discretion to do so. This policy applies to policyholder funds (Manulife’s “General Account” funds) and third-party client funds of Manulife Investment Management. This policy does not apply to investments where we do not have investment discretion such as index investments, unaffiliated fund mandates and client-directed managed accounts.
Manulife uses an independent third party to maintain an exclusion list of companies that manufacture cluster munitions. The exclusion list is updated on a quarterly basis.
Materiality
In 2024, we conducted a sustainability materiality assessment, engaging internal and external stakeholder groups to understand what sustainability issues are of greatest importance to our business.
We employ a double materiality approach in line with global best practices. This enables us to assess the potential impacts of sustainability issues on Manulife, as well as the external impact of Manulife on the economy, environment, and society.
The assessment allowed us to gain valuable insights into our key sustainability issues and foster ongoing engagement with our stakeholders. The outcomes from our stakeholder engagement process are presented in our annual Sustainability Report.
We aim to conduct a global materiality assessment on an annual basis to ensure our sustainability strategy remains up-to-date, reflective of, and aligned with both our business strategy and stakeholder expectations. The results of our materiality assessments have been reviewed by Manulife's Executive Sustainability Council as well as the Board of Directors’ Corporate Governance and Nominating Committee.
Materiality Assessment and Stakeholder Engagement
The following table identifies our key stakeholder groups, how we typically engage with them, and their primary topics of interest, as identified through the materiality assessment and our ongoing stakeholder interactions.
Stakeholder group
Ways we engage
Consumers/
customers
Digital products such as website and apps
Net Promoter System
In-person working sessions
Human-centred design
Call centres
Financial services professionals
Colleagues
Annual global employee engagement survey
Annual mid-year engagement action check-in survey
AskHR – Online HR resource
MFCentral – global colleague intranet and resource centre
Executive led Town Halls and Ask Me Anything sessions
Diversity, Equity, and Inclusion events
Employee resource groups
Online internal community forums
Fuel Up Fridays – afternoon of second Friday on each month is dedicated to learning
Wellness events and webinars
Podium – online recognition platform
Pursuit – online learning platform
Global monthly newsletter for leaders
Special in-person events – celebrations and social events at our different office locations
MFTVs – TV screens at our major locations
New Joiner Experience – how we welcome and support our newest team members
Stars of Excellence – annual colleague recognition program
Giving Campaign – annual campaign to encourage colleagues to give back to our communities
Segment / Function specific newsletters
Leader emails
Global Colleague Forum - annual live event for all colleagues globally
Shareholders/
investors
Shareholder engagement
Annual meeting
Investor events and presentations
Investor Day
Webcasts
Investor Relations website
Annual Report and Management Information Circular
Meetings, phone calls, and e-mail correspondence
Quarterly earnings results and earnings calls
Regulators
Mandatory local and regional reporting requirements
Voluntary reporting and engagement on key issues
Questionnaires
Industry associations
Engagement with and through industry associations to work on key issues
Questionnaires for industry research
Receive updates from industry associations
Participate on committees and working groups
Civil society/
NGOs
Ongoing dialogue with local and regional non-governmental organizations
Partnerships
Industry working groups
Funding research projects
Conferences and forums
Suppliers/
Vendors
Services and Technology
RFX: Requests for Proposals, Information, and Quotes
Contractual engagements
Governance reviews
Events and forum
3rd Party Vendor Risk Assessment
Communities
Philanthropic partnerships
Sponsorship of community events
Volunteerism
Employee giving and corporate match programs
Climate Action Plan
As a business, we are stronger when people and the planet thrive. Manulife recognizes the threats posed by climate change to our business, public health, and the livelihoods of the communities in which we operate, and the urgent need to preserve the quality of our natural environment. This includes how we manage our operations, how we make investment decisions, and how we develop and offer financial products and services.
Preserving our natural resources is critical to the well-being of future generations. Nature is at the heart of a healthy environment, and we believe in safeguarding forests, wetlands and natural habitats where biodiversity thrives.
Asset ownership
Nature is considered among various factors in General Account's evaluation of overall environmental risks and opportunities during the underwriting and monitoring of our investment portfolio, assessed when deemed material.
Asset management
At Manulife Investment Management, we view nature as our business. The forest and farms we manage are ecosystems, and our job is to keep them healthy and productive over the long term. We operate in a way that responsibly manages land and protects sensitive lands and biodiversity through stewardship practices. In our real estate, we have been actively engaging in initiatives to support nature and biodiversity within the built environment for several years.
One tool we believe to be invaluable for tracking progress on halting and reversing nature loss — as well as for informing decisions that will make this possible — is natural capital accounting. Moreover, it is a key component of our evolving approach to nature. Our approach entails construction of a natural capital asset register and materiality assessment, followed by valuation of natural capital assets and liabilities using a combination of internal company data and publicly available research.
Manulife Investment Management was a member of the informal working group for the Task Force on Nature-related Financial Disclosures (TNFD), working to develop the scope of that endeavor to deliver a risk management and disclosure framework for organizations to report and act on evolving nature-related risk. As the world’s largest institutional asset manager of natural capital, we have prioritized issuing our TNFD-aligned nature disclosure to further demonstrate our commitment to nature and our support of the framework.
In 2022, we launched our Impact Agenda, which articulates our commitment to building a better business to better the world.
Accordingly, our approach to Community Investment was updated to align to the Impact Agenda and its respective pillars—empowering sustained health and well-being, driving inclusive economic opportunity, and accelerating a sustainable future.
During the year, we informed our stakeholders, people, and partners, both internally and externally, about our new approach and continue to work to align our portfolio of Community Investment organizations to our new areas of focus. Our strategy prioritizes investments to organizations that:
Share a commitment to diversity, equity, and inclusion, particularly through representative leadership and targeted programming to historically underserved communities.
Drive community-centered solutions, working collaboratively across sectors, aimed at innovative and scalable initiatives.
Demonstrate a holistic approach to many aspects of well-being, including mental health, to improve and sustain positive outcomes over the long-term.
Utilize data to measure impact with key performance indicators and a commitment to reporting on progress.
Investment Focus: We focus on removing barriers and empowering people in the communities where we operate. With humanitarian and natural disasters happening around the world, we are committed to helping communities respond effectively with resiliency and recovery resources. We consider funding strategically aligned project or program specific grants, as well as capacity building grants or general operating support to organizations whose missions are highly aligned with our investment focus areas. In addition to programmatic funding, we also fund research and innovation to support cutting-edge ideas to understand, address, and promote sustainable change.
In line with our mission of making decisions easier and lives better, we support customers in their financial resilience journeys and prepare for potential challenges which lie ahead. Through our impact partners, we prioritize building financially resilient communities by providing access to opportunities for training, funding, and capacity building to community members. As a global financial services company, we look to extend the scope of our products, services, and partnerships to traditionally underserved demographics by assessing accessibility, affordability, and the unique needs of the various markets we operate in.
Our commitment to financial inclusion is reviewed as part of Manulife’s Executive Sustainability Council (ESC)’s mandate. The ESC consists of our Global Chief Sustainability Officer (CSO) along with eleven members of our Executive Leadership Team (ELT), including our Chief Executive Officer (CEO).
We leverage our expertise and resources to advance financial inclusion and literacy, which empowers individuals, families, and communities, to lay the foundation for economic prosperity:
We offer a number of specialized products and services that make our offerings more accessible, such as affordable critical illness and health insurance products, digitally enabled insurance products, and mobile banking solutions. We strive to innovate, expand on and assess the affordability of applicable products and services available to underserved communities.
Through our community investment and impact strategy, we support financial education and capability programs that seek to make a social impact by promoting financial well-being to underserved populations. We engage and partner with external organizations to support and enable global access to financial products and services (i.e microfinance).
We aim to:
Enable Behaviour/Attitude Changes
Increase awareness and action to set short-term and long-term financial goals that meet individual needs and expectations
Empower individuals to design and pursue career pathways
Increase Skills/Personal Effectiveness
Increase an individual’s ability to manage personal finances and/or help them gain new qualifications/skills
Improve Quality of Life/Well-being
Improve a sense of belonging, resilience, and greater social connections
Enable individuals to maintain meaningful employment in their industry of choice, increase their earning potential, and/or protect their financial security
Guiding and Enabling Policies
Our Conduct Risk Framework outlines best practices that our business should follow in all phases of the product and service cycle, including those regarding the fair treatment of customers.
Diversity, Equity and Inclusion
We live by our mission to make decisions easier and lives better. Foundational to our success is ensuring that all our employees, customers, and stakeholders are respected, feel connected to each other and our mission and are treated with equity and dignity, until each one of us belongs.
Our inclusive culture aims to inspire employees to bring their authentic selves to work, enabling them to provide high-quality service to our customers, business partners, and communities. We aspire to create an inclusive culture and brand with diverse talent that drives high performance. We understand the key to making a positive impact is embracing inclusion and leveraging it to create a stronger, more resilient organization. We take pride in setting ourselves apart from our competitors by placing inclusion at the heart of our efforts through four strategic pillars: Workforce, Workplace, Community, and Business.
Our Workforce – We aspire to have diversity at all levels in the organization that is reflective of the communities we operate and serve.
Our Workplace – We aim to create a workplace that is a safe and inclusive space, where everyone feels respected, valued, and heard.
Our Business – We incorporate an equity and inclusion lens to the development and delivery of products and services for our customers and communities.
Our Community – We invest in the community and organizations with an explicit focus on diversity, equity, and inclusion aimed at long-term positive impact towards marginalized groups, and partner with strategic organizations, who provide a layer of expertise on diversity-related subject matter.
Our global strategy is led by our Global Chief Diversity, Equity, and Inclusion Officer, the Global Diversity, Equity, and Inclusion team, and our Global Diversity, Equity, and Inclusion Council, who collectively guide, support, and facilitate its implementation. Chaired by our Chief Executive Officer and Chief Human Resources Officer, the Global Diversity, Equity, and Inclusion Council is made up of executive leaders who drive business impact through our strategy and play a key role representing business functions across the organization, with specific initiatives applicable to their respective functions. Council members meet as a group on a quarterly basis and act as advocates in their respective divisions and functions.
Employee Resource Groups
Our Employee Resource Groups (ERGs) are voluntary, employee-led networks that provide members with opportunities to connect with one another. They provide a space for them to build networks, share experiences, and contribute to our global inclusion efforts and are open to all colleagues.
Globally, Manulife has 15 Employee Resource Groups with 40 chapters and over 14,000 members:
Ability – building a positive and inclusive environment for colleagues of all abilities
AMP (Association of Multicultural Professionals) – promotes cultural awareness, cultivating talent and creating meaningful growth opportunities for multicultural professionals.
EMBRACE (Where Employees of Manulife Bridge Race, Culture and Ethnicity, to celebrate and uplift each other) – create an environment where communication and cooperation help members bridge race and culture and support each other in fully living their identities at work and beyond.
Family – a safe place where you can share your family experiences and get support.
GenerationNEXT – a community that helps to bridge the generation gap in our workplace by connecting colleagues who are looking for networking, career development and volunteer opportunities.
GWA (Global Women’s Alliance) – supports and encourages the recruitment, development and advancement of women throughout the organization.
IPTA (Indigenous Peoples and Their Allies) – aims to better enable Indigenous colleagues to advance professionally, have open and honest conversation while increasing the awareness of Indigenous Peoples.
LatinX – promote cultural awareness about Latin American diversity; and encourage inclusion through recruitment, development and career management for individuals representing this important community.
Male Allies – passionate about men and women working together to promote gender equality and the advancement of women.
MiLE (Military Employee Community) – a group for all employees who are current service members, veterans, and their families and supporters.
PACES (Pan-Asian Community for Employee Success) – strives to build the presence, influence and leadership potential of Pan-Asian employees at Manulife.
PROUD (Professionals Reaching out for Unity and Diversity) – promotes an inclusive workplace for LGBTQ+ employees to promote their full and unencumbered contribution to Manulife.
Shalom – mission to create an inclusive environment for Jewish colleagues and allies, as well as a forum to celebrate and share Jewish heritage and identity.
Sustainability Hub – a forum created to engage colleagues and help them learn about sustainability, both personally and through the lens of Manulife.
VIBE (Valuing the Inclusion of Black Experiences) – aims to better enable our Black employees to advance professionally, support the aspirations of potential employees and increase awareness of various Black cultures.
Pay Equity
We are committed to pay equity and to providing all colleagues with fair and equitable pay opportunities. Our commitment starts with our unbiased job evaluation process and global job architecture around which our compensation structures and programs are designed. These foundational pieces are central to ensuring work across the organization is valued fairly using a consistently applied methodology. We have created a pay-for-performance environment where everyone’s compensation is tied to the impact they have on the business and to their performance, including both “what” they achieve and “how” they achieve it.
We take ongoing steps to identify and mitigate the risk of unconscious bias in our pay practices and to ensure equitable compensation outcomes for our employees.
To track and measure our pay equity success, we conduct detailed quarterly comparative compensation analyses to ensure that compensation across gender, racial minorities is equitable after considering differences in job level, job families, tenure, specialized skills, and individual performance.
Responsible Procurement
Manulife is committed to a steadfast approach to responsible procurement by incorporating environmental and social practices into our sourcing decisions to help the organization buy better. Manulife aligns with vendors who share similar values, including vendors who are committed to maintaining continuous stewardship in environmental and social sustainability within the entire value chain.
Manulife's Global Procurement and Third-Party Management Standard provides guidance on delivering the best value with all third-party purchases, and that all dealings with third parties are conducted in a manner in line with Manulife’s Code of Business Conduct and Ethics. This standard enables procurement to maximize the provision of products and services and minimize risk while upholding our high ethical standards in working with vendors.
Our updated Vendor Code of Conduct sets clear guidelines for our vendors, with key clauses that reinforces our commitment to fostering a supply chain network that prioritizes environmental protection and the wellness and fair treatment of their employees.
Ethical business practices and good governance are integral to our legacy and long-term success. We support businesses owned by underrepresented communities and minorities as part of our effort to reflect the diversity of the communities in which we operate.
Talent Management
Talent Attraction and Retention
To find the talent we need to deliver on our strategic objectives, our approach to talent attraction is focused on building inclusive talent networks to attract top talent in a highly competitive market. Our focus on delivering innovative ways to find and engage candidates centers around personalized experiences enabled by leading technology and capabilities.
Employees can call, email or chat directly with a live agent through our AskHR website with any questions relating to HR policies and benefits programs, or to raise concerns. With representatives located across our global footprint, AskHR is always ready to support employees and managers globally.
Training and Development
We are committed to creating a workplace that offers unlimited opportunities for employees to realize their career goals. Employees want to work for an organization they believe cares for them, values their perspective and contributions, invests in them, and gives them flexibility to deliver great work. Whether it is working abroad, exploring a new career direction, or simply progressing in their chosen field, we help our employees reach their full potential through focused development programs and online resources. We provide employees with opportunities for learning and development at all stages of their career. In addition to on-the-job training, mentoring, coaching, in-house programs, and online learning resources, we often subsidize the cost of continuous learning and examinations as employees pursue their learning and individual development plans.
Our vision is to provide a high-quality learning experience that empowers our employees to learn anytime, anywhere. Manulife focuses on offering employees learning opportunities to enable them to work more innovatively and collaboratively and to accelerate our ambition of being the most digital, customer-centric global company in our industry.
On an annual basis, all employees must participate in the following mandatory training courses: Code of Business Conduct and Ethics Training and Certification, Anti-Money Laundering and Anti-Terrorist Financing Training, Information Protection Training Preventing, and Discrimination, Harassment and Workplace Violence.
Engagement and Recognition
Our ability to engage the best, diverse talent is critical to retention. As individuals are focused on working for organizations that align with their values, we believe our culture gives us a competitive edge. Listening to our people, and understanding what’s most important to them, are key components of our approach to building engagement. We facilitate employee listening through a variety of platforms and channels.
Engagement Survey: Our annual engagement survey is an opportunity for all our employees to tell us what we’re doing well and what we could enhance to help everyone feel connected, empowered and supported. Our full employee engagement survey, which is run in the Fall, is designed to focus on the topics that have the greatest impact on employees’ engagement. We also run a short pulse survey in the Spring as a check-in on action planning progress, as well as additional topics that might be an area of focus. Grounded in the model of Share-Plan-Act, there is a strong focus on sharing survey findings and taking action at the team level so that everyone is involved in building a more engaging workplace. Our target as an organization is to have top quartile engagement as it relates to the Gallup Finance & Insurance companies database.
Recognition Programs: Recognition is a key driver of engagement and as such we have two globally adopted recognition programs: Podium and Stars of Excellence. Podium is a digital recognition platform that allows employees to recognize one another for day-to-day contributions and their service anniversaries. Stars of Excellence is our premier annual recognition program to recognize the top 150 employees for achievements in the previous calendar year.
Performance Enablement Program: Our annual Performance Enablement process uses a Management by Objectives approach which includes Goal setting, Mid-Year and Year-End Check Ins, encourages discussion and documentation of performance against determined objectives/goals, development plans, and agreement on deliverables, development needs, career aspirations and specific training actions and timelines. We have a performance enablement system to enable the exchange of feedback, create and update goals, and document performance reviews for all employees globally. An emphasis on feedback and conversations is core to the performance enablement program. Feedback is encouraged through different mediums and exchanging feedback anytime throughout the year is made possible through our systems. This Ongoing check-in approach keeps leaders and employees connected throughout the year on their set goals and development progress. To stress the importance of leadership, their annual Leadership goal is auto assigned in our systems for all people leaders globally. The goal can be updated to allow for greater personalization of specific actions and success measures by individual people leaders. Both Mid-Year and Year-End reviews are completed and acknowledged by the employee and people leader.
Employee Health and Wellness
One of Manulife’s key priorities is protecting and supporting the health and wellbeing of our colleagues. We strive to support the diverse nature of our workforce, and we prioritize their health, safety and wellbeing through the following means:
Providing colleagues with a comprehensive benefits package that supports them and their families
Flexibility when it comes to their benefits and wellbeing choices
Supporting the evolving needs of our colleagues and enhancing our benefits and wellbeing offerings
Ensuring compliance with legislative requirements
Our employee programs cover a wide array of benefits plans with options that employees can tailor to their individual needs. Our benefits and wellness programs vary by region and may include:
Health, dental, vision, short-term disability, long-term disability, and life insurance coverage
Retirement savings plans
Care and support for employees with cancer
Mental health support and benefits
Extra Personal Days for employees to use during each calendar year
Family friendly benefits for families of all kinds and family planning, including fertility support, and financial support for adoption and surrogacy
Maternity, parental and adoption leaves above statutory requirements, including paid maternity, parental and adoption leaves, in certain geographies. In North America we offer:
20 weeks paid parental leave for the primary caregiver, and 12 weeks paid parental leave for the non-primary caregiver
12 weeks paid adoption leave for non-birth parents
Adoption and surrogacy benefits that reimburses for eligible expense to a maximum of $20,000 per adoption and $20,000 per surrogacy.
Designated breastfeeding facilities and parenting rooms in many of our corporate offices
Emergency childcare and eldercare subsidies
Ability to expense childcare through a flexible wellness account via employee benefits, up to the available maximum
Our U.S. and Canada colleagues have access to 20 days of back-up childcare per dependent per year at employee subsidized rates
Gender reassignment coverage in many jurisdictions
Flexible work programs and working hours following a human-centered approach, so employees can manage their time and personal schedules
Some positions offer part-time contracts
Some positions offer full-time remote work, or a hybrid working from home arrangement
Access to industry-leading expertise and financial products to help employees optimize their own financial planning
Healthy workspaces, including healthy food options in cafeterias and amenity spaces supporting wellness at several locations.
Onsite fitness facilities with group fitness classes including yoga at several locations
Ability to expense fitness equipment, gym memberships and fitness app costs through a flexible wellness account via employee benefits
Occupational Health and Safety
Our Global Health and Safety program embodies its commitment to providing a safe and healthy workplace in compliance with legislative occupational health and safety requirements. This commitment to health and safety is an integral part of our operations and involves the co-operation and support of every individual within the Company.
All employees have a responsibility for fostering a healthy and safe working environment:
Our global Working Better Program helps guide how we manage work schedules and connect with each other to boost our effectiveness.
Senior management is responsible for enforcement of Manulife’s Global Health and Safety Policy and for ensuring that Health and Safety Committees are established as required by law. Leaders are held accountable for the safety of employees under their supervision. This includes ensuring that equipment is safe and that employees work in compliance with established safe work practices and procedures.
Our Global Health and Safety Policy recognizes that everyone in the organization has specific responsibilities for Occupational Health and Safety integrated into everyone’s job. This includes:
Encouraging all colleagues to comply with all company operating procedures pertaining to health and safety and empowering them to take ownership of their safety and report any concerns.
Encouraging colleagues, supervisors, and senior management to raise and resolve health and safety issues as part of their daily business duties. Referring items to senior management if the department manager/supervisor is unable to correct the issue and encourage use of the Joint Health and Safety Committee, Health and Safety teams, and Employee Relations.
Our workplace policies and programs prioritize prevention, monitoring of our health and safety procedures, and training. This includes procedures to investigate work-related injuries, illnesses, diseases, and incidents. For instance, if a slip and fall occurs, there is an emergency procedure followed to appropriately attend to the individual. An employee incident report form and an incident/ hazard investigation form are completed to help ensure any deficiencies are corrected. Our workplaces have emergency response plans to identify risks and to plan for emergency situations to premises and employees, and we identify actions required to prepare for, and respond to, emergency situations. Internal inspections including health and safety workplace, security, and real estate/building operations are completed. Hazards and risks noted during inspections are escalated to the appropriate teams, and issued remediation works are monitored to track completion.
To develop a culture where employees value the health and safety of themselves and others, we provide employee education, including how to report health and safety incidents, health and safety training, first aid and mental health first aid training for key individuals, and training on our Global Discrimination, Harassment and Workplace Violence Policy.
Customer Experience
Customer Experience and NPS: Delivering great customer experience starts with listening closely to our customers, learning from their signals and cues and responding quickly with action. Through our Net Promoter System (NPS), enabled in all of our business globally, we collect real-time feedback from customers at all key moments of interaction. This transactional feedback is delivered directly to the teams that are empowered to take steps to fix or change the customer experience. We are continually maturing our NPS system, ensuring we have the best coverage across key touchpoints and the right people in place to act on real-time feedback.
Customer complaint resolution: We are committed to providing high-quality service and products to assist customers in making better financial decisions. If customers have questions or concerns, we see it as our responsibility to respond promptly, accurately and with the utmost courtesy. Our websites outline complaint resolution processes in each region. The Audit Committee annually reviews the procedures for dealing with customer complaints.
Customer Longevity
When customers lead longer, healthier lives, it benefits them, their life insurers, and society as a whole. As a life insurer, retirement plan provider, and asset manager, we are well-positioned to help our customers achieve a healthier, longer life underpinned with financial resilience to enjoy life to its fullest.
Behavioural Insurance: We are at the leading edge of behavioural insurance, a shared value approach to life insurance that encourages customers to take small steps every day towards living longer, healthier, better lives.
When customers live longer, healthier lives, it is good for them and for their life insurers, while society benefits as a whole — it is a primary example of bringing the principles of shared value to life.
Whereas traditional insurance policies are priced based on a limited snapshot of a customer’s data (e.g., age, smoking status, gender, basic health indicators) at the point of purchase, this new type of insurance provides financial protection and rewards customers with premium savings and other benefits when they make healthy lifestyle choices.
Through our behavioural insurance products across Canada, the U.S., and select markets in Asia, we support customers in living healthier, more active lives by rewarding them for making healthy lifestyle choices. We offer four behavioural insurance programs in Canada (Manulife Vitality), the U.S. (John Hancock Vitality), and in select markets in Asia (ManulifeMOVE).
Life and Health Insurance: Manulife aims to be at the forefront of analysis of the impacts of climate change on products and underwriting for life and health insurance. These impacts range in severity and complexity, from acute illness to chronic stress.
Our approach includes an interdisciplinary team of Manulife professionals that undertake research to understand the human impacts of climate change, build awareness of human impacts across the business, and engage with external experts on relevant initiatives. Our focus is on research and data collection to inform products, product pricing, underwriting, claims, and actuaries as we learn more about the impact of physical climate-related risks on morbidity and mortality rates.
Our changing climate has an impact on human health. Every country and individual will be affected, with vulnerable populations at greatest risk. We believe that the work undertaken by our business benefits Manulife’s ability to manage climate-related risks and opportunities and respond to client needs.
Our guidelines and customer pricing are based on historical data, and we continuously seek to understand how changes in our environment may impact our customers through shifts in incidence rate or severity of certain conditions. We have frameworks in place to study the experience and inform decisions that lead to changes. We have a country classification process that requires us to analyze risks associated with each country where we sell products. We include environmental risks factors as part of the scoring, and we refresh the scores every three years to allow us to take into account any significant shifts in experience. Our claims experience together with the results of the country classification process are then reflected as adjustments to products, underwriting guidelines, or pricing.
Aging is also a key consideration. We understand that each age group comes with different risks, and we underwrite according to those risks. The elderly population has unique risks, which we have covered in our proprietary underwriting guidelines. We consider factors such as mobility, cognition, weight loss, and complex co-morbidities and generally require that our most experienced underwriters review these cases. We often require older age exams specifically designed for the older ages.
Manulife has a proprietary life insurance manual that is managed and maintained to reflect multiple risks including environmental impacts, obesity, emerging health issues, and other topics. We have a steering committee comprised of medical directors, chief underwriters, research underwriters, risk managers, actuaries, and others to ensure we stay abreast of changes. Our experts review publications in all major medical journals and our internal experience from claims to make informed decisions and update the manual.
Financial Resilience
As people around the globe live longer, building financial resilience becomes even more critical. Financial resilience is the ability to navigate and bounce back from the financial obstacles that occur throughout our lives, such as debt, healthcare costs, emergencies, and unexpected life events. Longevity brings with it a new wave of obstacles and decisions people must face, from managing family care, housing, healthcare, and education to the services, products, and technologies that they’ll require as they age. We help people around the world confidently save and invest for their longer lives through engagement, education, and advice. We support and promote digital engagement to help individuals take control of their longer financial lives. We provide financial education to help them build the knowledge and confidence they need to navigate this new territory. And we help individuals through their working and post-career years with access to advice and financial education.
Human Rights
Our approach to respecting and promoting human rights is guided by the United Nations Guiding Principles on Business and Human Rights and the International Labour Organization (ILO) core conventions. Manulife is firmly committed to respecting human rights in our business and throughout our supply chain.
Throughout our organization, our teams act in accordance with Manulife’s Code of Business Conduct and Ethics, which affirms our commitment to ethical conduct and to operating within the laws and regulations of every jurisdiction in which we operate. All active Manulife employees and contractors are required to complete annual training related to Manulife’s Code of Business Conduct and Ethics.
Across Manulife’s global business, we have policies and frameworks in place to manage human rights risks, including modern slavery risks. We believe ethical business practices and good governance are integral to how we conduct our business and to our long-term success. Achieving our objectives requires a commitment to integrity and consistent high standards from all our partners, including our employees and vendors, through compliance with a framework of policies that help us manage our business.
Our policies and standards are guided by international principles, as well as the letter and spirit of all applicable laws and regulations. We take steps to ensure our partners are aware of their obligations, and institute appropriate due diligence and monitoring to detect human rights violations in our supply chain. To ensure our key controls are effectively designed and executed, we subject our controls to ongoing quality assurance testing coupled with independent monitoring and testing from our Second and Third Lines of defense, for example, by Enterprise Risk Management and internal or external Audit.
Examples of policies we have implemented to mitigate human rights risks include:
Manulife Code of Business Conduct and Ethics (“the Code”), which reiterates our commitment to ethical conduct and our practice of complying with all applicable laws.
Global Human Rights Statement which demonstrates our commitment to respecting and promoting internationally proclaimed human rights.
Vendor Code of Conduct, which requires all of Manulife’s vendors to adhere to.
Global Health and Safety Policy detailing our commitment to health and safety in the workplace.
Global Discrimination, Harassment and Workplace Violence Policy which aims to address discrimination, harassment, and violence from all individuals with whom we come into contact in the workplace, including employees, contingent workers, contractors, customers, clients and third parties.
As a member of the UN Global Compact, Manulife provides all employees with access to the UN Global Compact Academy, which includes various modules on human rights. Furthermore, selected employees have participated in the UN Global Compact’s Business and Human Rights accelerator program.
Financial Crimes
We adhere to all applicable anti-money laundering and terrorist financing laws and regulatory requirements in the jurisdictions in which we operate, including guidance on money laundering risk related to modern slavery and human trafficking. Our Compliance, Global Investigative & Forensic Services, and Corporate Security functions work to address matters of modern slavery to both proactively assess effectiveness of our due diligence practices, and to respond to any complaints. The risks these programs monitor for include but are not limited to human trafficking, forced labour and debt bondage. The programs in place are designed to educate relevant employees and develop resources for customers to seek assistance. Together, our internal teams work with community resource groups, and law enforcement to raise awareness and provide education to combat modern slavery.
Our approach to risk management is governed by our Enterprise Risk Management ("ERM") Framework. The ERM Framework is a foundational, holistic, compliant, integrated, and adaptive approach to understanding and managing risk while balancing the need to remain competitive. This structure is designed to provide guardrails on our risk profile while optimizing risk-adjusted returns without compromising our ability to meet our commitments.
The ERM Framework is comprised of five interrelated components: Risk Taxonomy, Risk Appetite, Risk Governance, Risk Process, and Risk Culture.
Risk Taxonomy
Our businesses and operations expose Manulife to a broad range of risks. The Risk Taxonomy categorizes and defines these potentially material risks. It creates a common risk language and provides reasonable assurance that risks are consistently understood and managed.
The Risk Taxonomy is a core element of the ERM Framework, supporting all other components. It provides the basis for policy and committee coverage (Risk Governance), enables risk identification (Risk Process), reasonably assures that Risk Appetite Statements and Limits are established for material risks (Risk Appetite), and clarifies who is accountable for managing each risk (Risk Culture).
Risk Appetite
The Risk Appetite Framework (“RAF”) guides risk taking by establishing our Risk Appetite, which is the aggregate level of each type of risk we are prepared to accept in pursuit of our strategic priorities, as well as how much additional risk we can tolerate before reaching Risk Limits established by the risk committee of MFC’s board of directors (the “Board”).
The RAF creates a balanced view of risk and return that promotes sustainable growth and resilience, supports informed decision-making, and fosters prudent Risk Culture. The RAF is integral to the Board and management discussions and decision-making. They receive regular reports on the RAF’s effectiveness and compliance, including comparisons of actual results versus stated RAF measures, and notification of any limit breaches and corresponding action plans. Risk Appetite Statements are designed to provide guardrails on our appetite for identified risks.
Risk Governance
Risk Governance is intended to provide an organized, hierarchical approach to risk management oversight. It is articulated in policies and executed through a Three Lines Operating Model that is supported by a risk committee structure. Requirements, limits, and decisions are cascaded top-down; issues, escalations, and reporting are raised bottom-up.
Risk Process
The Risk Process involves the First Line managing risk in alignment with the RAF and within Risk Limits, and the Second Line overseeing risk management and providing objective challenge. It entails the First Line and the Second Line independently identifying, assessing, monitoring, and reporting on our current risk profile and our risk profile under stressed conditions at both the segment and Company levels, with appropriate controls and documentation.
Risk Culture
The Company is committed to a set of shared values, which reflect our culture, inform our behaviours, actions, and decisions, and help define how we work together.
Risk Culture is a subset of the Company’s culture; it reflects norms of behaviours, actions, and decisions in relation to risk awareness, risk taking, and risk oversight. A sound Risk Culture balances risk-return to remain within Risk Appetite and in alignment with the ERM Framework. It emphasizes the importance of maintaining an effective control environment. It promptly detects and remediates policy/limit breaches and operational incidents, and then follows up to understand root causes, enhances preventative and detective controls, and takes appropriate disciplinary action if warranted.
We pride ourselves on honesty, integrity, and an uncompromising dedication to the highest standards of business conduct. We have a reputation within the industry that speaks to our moral compass and professionalism when it comes to our ethics and compliance culture.
Manulife's Code of Business Conduct and Ethics (the “Code”) affirms the company’s commitment to ethical conduct and its practice of complying with all applicable laws and avoiding potential or actual conflicts of interest. The Board of Directors, with the support of the Audit Committee, oversees compliance with the Code and reviews and approves the Code on an annual basis.
Our employees and all members of Manulife’s Board of Directors receive 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. Employees are also required to comply with all relevant laws and regulations, as well as internal policies, standards and guidelines. In addition to providing compulsory and supplemental training that includes annual mandatory training on the Code, we run specialized employee communication campaigns to reinforce our well-established culture of compliance. These campaigns and training cover topics such as fraud, cyber security, risk awareness, data privacy and security.
Ethical Business Practices
Manulife is committed to ethical business practices across its global operations. Management maintains an uncompromising stance against fraud and misconduct, whether perpetrated by its personnel or by individuals acting on its behalf. While management rigorously addresses every known instance of fraud, it acknowledges that the size and scope of the business make it impossible to prevent all cases of fraud and misconduct. Consequently, Manulife accepts fraud risk losses within the monetary boundaries defined by the enterprise risk appetite.
The Global Anti-Fraud Officer is responsible for second line of defense oversight and coordination of the Company’s Anti-Fraud efforts. This oversight and leadership are global in nature requiring the Global Anti-Fraud Officer to coordinate with the other control functions and report and advise the parent and subsidiaries worldwide on all anti-fraud and anti- corruption requirements, as well as privacy, data security and third-party due diligence where issues relate to suspected fraudulent or intentional misconduct. Manulife has a global issues and corrective action plans (CAPs) management process where issues and corrective action plans are reported to senior leadership and tracker closely until implementation and closure. Our Anti-Fraud Policy includes a set of internal fraud reporting thresholds and a quarterly reporting requirement to help ensure that fraud reporting information is escalated on a timely basis. The Global Anti-Fraud Standards contain Manulife’s Fraud Risk Appetite Statement, a description of the Company’s anti-fraud organizational structure, roles and responsibilities of each related function and the minimum control requirements throughout the fraud risk management process from identification to mitigation to reporting.
The Anti-Fraud Monitoring process includes:
An assessment of the nature of Ethics Hotline matters, the disposition of such matters, and the segments in which those matters arise.
Review and follow-up of issues and corrective action plants with a nexus to fraud.
Quarterly global segments anti-fraud forums
Bi-weekly Anti-fraud Fusion Center meetings which consists of members from Anti-Fraud Operations, Cyber Security, GIFS, Privacy, Corporate Security and Anti-Money Laundering/Anti-Terrorist Financing, Global Fraud Analytics COE, and Global Anti-Fraud Office.
Quarterly self-assessment of overall internal control effectiveness
Annual global fraud risk self-assessment
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 as part of their obligations to comply with Manulife’s Vendor Code of Conduct.
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) and law enforcement where necessary.
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.
A critical component of the Manulife control environment is the focus on development of employees through relevant independent accreditation programs. Manulife employees responsible for the ongoing effective execution of our key compliance related controls have received certifications and designations from independent accreditors in their respective areas of risk such as Anti-Fraud (e.g., Certified Fraud Examiners), Anti-Money Laundering (e.g., Certified Anti-Money Laundering Specialist), Anti-Bribery and Corruption and Code of Conduct (e.g., Certified Financial Crime Specialist).
Manulife’s support teams, such as second line of defense Investigative and Forensic Services (e.g., Certified Professional Investigator) and Audit Services (e.g., Certified Internal Auditor) representing the third line of defense also obtain relevant designations and certifications to fulfill their respective responsibilities within the control environment.
Manulife also provides training on ethical standards for all employees, including part time employees and contingent workers where applicable. Training topics and scenarios include:
Information Protection
Anti-Fraud
Reporting Unethical Conduct
Insider Trading
Social Media Usage
Using Company Assets
Avoiding Conflicts of Interest
Working with Suppliers and Counterparties
Government and Political Dealings
Anti-Bribery and Anti-Corruption
Diversity, Equity, and Inclusion Messaging
Using informative case studies, our training also spotlights the areas of emerging risk, such as the use of unapproved communications channels, electronic communications including the use of new technology (e.g. ChatGPT), potential ESG risks (e.g., greenwashing), and sales culture and conduct. The training incorporated enhanced sections on financial crimes, and unapproved “off-channel” communications. New case studies were added on conduct and culture, artificial intelligence, foreign inference reporting and truthfulness in responding to audits and investigations.
Reporting on breaches
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 2024 we made updates to our Ethics Hotline Procedures. Reports of alleged misconduct received are handled in three phases: Intake Phase, Investigation Phase; and Resolution Phase.
The Intake Phase includes the receipt of a report, determination by the Global Ethics Office concerning the issues raised, and determination of the relevant segment. The Global Ethics Office provides a preliminary response to the reporter to acknowledge receipt of the report. The matter may be channeled to the applicable Segment Compliance Officer or others as appropriate. An action plan is developed based on the issue and complexity of the matter, and additional information is gathered as needed. In sensitive matters, the Global Ethics Office may lead the investigation.
During the Investigation Phase, the Global Ethics Office or relevant Segment Compliance Officer assigns an individual to lead the investigation and coordinate the fact-gathering process. This includes interviewing personnel, gathering documents/records, and obtaining background information. The lead investigator provides periodic updates on the investigation to the Global Ethics Office, which may notify the reporter of any further questions or updates.
In the Resolution Phase, the Global Ethics Office determines whether administrative and/or remedial action is warranted. If no action is warranted, the matter is closed, and a closing note is posted on the Ethics Hotline system. If action is warranted, the Global Ethics Office confers with appropriate management, compliance, and/or ER/HR personnel to develop and implement an action plan. Once resolved, a closing note is posted on the Ethics Hotline system.
Tax Transparency
Our tax strategy is based on the following principles:
Complete honesty and integrity
Compliance with all applicable laws and regulations, including transfer pricing guidelines
Contribution to shareholder value
Customer-centric client service
Protection of the Manulife brand and reputation
Operational efficiency and effectiveness
Openness and co-operation with tax authorities
Tax falls within the scope of the Chief Financial Officer’s responsibilities. Ultimate responsibility is with our Executive Leadership Team and Manulife’s Board of Directors. Operational responsibility for tax strategy and risk management resides with Global Tax.
We have established formal committees to review and approve significant transactions and structures. Such committees are accountable to the Executive Leadership team and/or Manulife’s Board of Directors as is deemed appropriate. Manulife’s Global Tax department participates in these committees and Global Tax’s approval is required for transactions and structures with significant tax implications.
We have a global presence operating in numerous countries around the world, each with its own taxation system and tax rates. We comply with transfer pricing legislation and guidelines established by the countries in which we operate, along with OECD transfer pricing guidelines, to ensure that the “arm’s-length” principle is observed in pricing cross-border transactions between Manulife entities. Also, in accordance with the OECD’s Base Erosion and Profit Shifting initiative (BEPS) to enhance tax transparency, we produces country-by-country reporting on our global operations to facilitate the audit work of tax authorities around the world.
Data Security and Privacy
Information risk is a top enterprise risk management priority, similar to financial or credit risk. We seek to protect our data, that of our customers, and the information systems that process, transmit, and store that data. Global, local, and cross-functional teams work collaboratively to reasonably ensure a cohesive, effective, and efficient program for protecting all forms of information under Manulife’s control.
Information and Cyber Security Governance
The Manulife Chief Information Risk Officer oversees our enterprise-wide Information Risk Management program, and the Manulife Chief Information Security Officer, who reports to the Chief Information Risk Officer, oversees our enterprise-wide Information Security Management program. These programs establish the company’s information and cybersecurity framework, governance, policies, standards, and appropriate controls required to protect our information and computer systems.
On at least a quarterly basis, the Manulife Chief Information Risk Officer speaks to the Board Risk Committee to cover recent notable events, audit results, the overall ongoing effectiveness of information and cybersecurity controls, operations, and opportunities for improvement and maturity, among other items.
Manulife employees participate in mandatory annual security and privacy training to ensure our workforce is knowledgeable about their responsibilities to protect company and customer information. They can access related policies, standards, and procedures at any time through a centralized website, and global communication campaigns about protecting information are conducted quarterly, highlighting information protection topics and delivering simple, action-oriented messages. Phishing campaigns are run annually with simulated phishing email messages to educate employees on how to recognize and address suspicious emails.
There are several ways Manulife colleagues can escalate suspicious communications, events and incidents, including privacy, fraud, ethical, security, and operational matters. Depending on the incident type, colleagues may be encouraged to report the matter directly to their manager or a senior executive. In other cases, colleagues are encouraged to report directly to a confidential hotline or designated departmental inbox. In all cases, if a colleague is unsure where to start, Manulife has a central global platform where any potential or actual issue can be escalated via a web form, email, or phone call with assurance that the matter will go through a timely triage review and forwarded to the appropriate team for further analysis and action.
Data Privacy
We have a global framework for managing the Company’s privacy risk, which is overseen by our Global Chief Privacy Officer, who is accountable to the Global Compliance Chief. The framework is anchored by our Global Privacy Risk Management Policy and designed to:
Help ensure compliance with legal and regulatory requirements governing the protection of personal information in all the jurisdictions in which we operate, while also promoting consistency in personal information handling practices throughout the Company.
Maintain and foster customer and employee trust.
Minimize the occurrence and impact of privacy-related incidents.
Our framework establishes standards for:
Ensuring applicable privacy legislation and regulations are understood and requirements reflected in applicable business processes, controls, and disclosures.
Identifying and managing privacy-related risks, including those that may be introduced by new or changed initiatives.
Collecting and handling personal information, including limiting collection and ensuring it is carried out in fair and legal ways.
Handling requests from individuals, including privacy-related complaints, concerns, and consent withdrawals.
Privacy incident management, including root cause analysis and corrective actions.
Sharing personal information with third parties, requiring them to comply with our internal framework through privacy and security clauses within contracts.
Safeguarding personal information.
Monitoring compliance with the framework.
Reporting, managing, and escalating all privacy-related complaints to appropriate levels within the company.
Privacy and data security training for all employees, including part-time and contractors.
The Global Privacy Policy outlines Manulife's fundamental privacy requirements applicable to all businesses and operations world-wide. In many of the countries in which we do business the Global Privacy Policy is supplemented by more detailed privacy policies that reflect the requirements of those countries. Our Global Privacy Policy and our internal-facing corporate privacy policy follow the Generally Accepted Privacy Principles (GAPP). Specifically:
Management
Roles, responsibilities, and requirements for appropriate handling of personal information are well defined and communicated.
Notice
Manulife provides notice to data subjects via our published privacy policies and other disclosures. Our privacy policies are published on our websites, including in local languages where applicable.
Choice and consent
We gather consent for specific purposes, where required.
We provide data subjects with choices for how their personal information is handled, where appropriate or permitted by law.
Collection
We only collect personal information that is required for specific purposes, such as providing products and services, conducting business, better understanding our customers' needs, or where it is required or allowed by law.
Use, retention, and disposal
We only use and retain personal information for the purposes for which it’s collected, for other purposes you consent to, or when it is required or allowed by law.
We keep personal information only as long as needed to satisfy the purposes for which it was collected or as required or allowed by law.
When personal information is no longer required to meet the specific purposes, it is destroyed, erased, or made anonymous.
Access
Upon written request, we will provide a data subject with reasonable access to their personal information and a description of its use or disclosure, as required or permitted by law.
Disclosure to third parties
We are responsible for personal information in our possession, including information transferred to service providers who perform duties on our behalf. When we share personal information with our service providers, we require them to protect it and handle it in ways that are consistent with our privacy policies and practices.
We only disclose personal information for the purposes for which it’s collected, for other purposes the data subject has consented to, or when it is required or allowed by law. This may include sharing personal information with reinsurers, with our agents or representatives or with our service providers.
In some cases, and where allowed by law, we may share personal information within the Manulife group of companies in order to provide our customers with offers for other products or services. Data subjects may opt out of receiving those offers.
Security for privacy
We protect personal information with security safeguards that are appropriate to the sensitivity of the information, in order to protect it from unauthorized access, release, modification or use.
All our employees are required to complete annual privacy and security training.
We will protect personal information with security safeguards that are appropriate to the sensitivity of the information, in order to protect it from unauthorized access, release, modification or use.
All our employees are required to complete annual privacy and security training.
Quality
Data subjects may verify the accuracy and completeness of their personal information, and request that it be amended or deleted, if appropriate or permitted by law.
We aim to keep our records of personal information as accurate and up to date as is necessary to fulfill the purposes for which it is collection, used, and retained.
Monitoring & enforcement
We are committed to handling the personal information under our control with care. We have designated individuals who are responsible for monitoring our ongoing compliance with our privacy policies.
As a provider of financial products and services, we collect and use our customers’ personal information through the normal course of our business. When Manulife shares personal information within the Manulife group of companies for the purposes of providing customers with product and service offerings, customers may opt-out of receiving those offers. Other opt-out options may be available to certain customers depending on their product(s) and/or location. Our customers trust that we will safeguard the privacy of the information in our care, and we take this responsibility very seriously. When we share personal information with our service providers it is for specific purposes only. Service providers who collect, use, process, maintain, transfer, and / or destroy personal information on Manulife's behalf must comply with applicable privacy laws and non-disclosure agreements, have adequate privacy safeguards in place, and must only use the information for the purpose(s) provided for in a contractual agreement. We have contractual agreements in place requiring our service providers to protect and handle personal information on our behalf in ways that are consistent with our privacy policies and practices. This is aligned with the OECD’s Accountability Principle. Service providers are also obligated to report any privacy incidents and issues to us within specified timeframes.
Details given to customers about how we handle their personal information include:
The nature of information collected, the specific purposes for its collection, and how it is collected
How the collected information is used
Any options they may have for deciding how their personal information is collected, used, retained, and processed
How long the information is retained
Safeguards required to protect the information
Sharing of personal information with service providers
How to contact us if they have questions, concerns, or require access to their personal information
Our executive compensation program focuses named executives on achieving long-term sustainable growth and on creating significant value for our shareholders and customers. It is designed to attract and retain high caliber executive talent capable of achieving our ambitious goals and contributing to our competitive advantage.
Our approach is centered on pay for performance, and supported by five principles that guide our program design, compensation decisions and administrative practices.
Executive compensation is linked to strong risk-managed performance. Most of what our executives earn is variable, tied to performance and not guaranteed. In practice, executives ultimately receive more when performance is strong and earn less when performance is mixed.
Managing conduct risk is central to our values of Obsessing about Customers and Doing the Right Thing. Our values underpin our commitment to treating customers fairly and ensuring positive customer interactions. We are focused on the responsibility we have to customers – as a leading international financial services provider, helping people make their decisions easier and lives better, we aim to meet the needs of our customers while supporting the needs of future generations.
We constantly develop our practices and processes to deliver fair treatment for our customers. These include strong protection of private information, plain language communication with customers, responsive customer service and complaint handling processes. We ensure our products are clearly explained and honestly marketed so our customers can make informed decisions and choose products and services that are most beneficial to them.
We actively participate in industry dialogue with regulators and industry associations to provide feedback on potential regulations and learn more about regulatory expectations. This enables us to be at the forefront of best practices that our business should follow in all phases of the product and service cycle, including those regarding the fair treatment of customers.
Policy dialogue and participation improves our ability to understand and address critical issues, and to make strategic decisions that benefit our stakeholders. Public policy discussions can also be directly relevant to the evolving legislative and regulatory requirements under which Manulife and our financial services products are governed.
For additional information, refer to Manulife's 2024 Political Activities and Contributions Report.
In early 2019, Environmental, Social and Governance (ESG), oversight was added to the charter of the Board’s Corporate Governance and Nominating Committee. The Committee reviews our sustainability strategy progress and stays informed of ESG trends, risks and opportunities through management reporting. Members of the Committee include the Board Chair and five independent Board members.
The Committee’s oversight of ESG complements the work of the Executive Sustainability Council (ESC). The ESC, which consists of eight members of our executive leadership team, is responsible for establishing the enterprise’s sustainability ambition, guiding the development of the sustainability strategy and providing recommendations and direction on matters related to sustainability. In addition to the ESC, we have a subsidiary-specific committee that executes asset class specific sustainability objectives.
The following are our Sustainability related policies and position statements that guide our work:
Manulife will not knowingly make direct investments in companies that manufacture cluster munitions where we have discretion to do so. This policy applies to policyholder funds (Manulife’s “General Account” funds) and third-party client funds of Manulife Investment Management. This policy does not apply to investments where we do not have investment discretion such as index investments, unaffiliated fund mandates and client-directed managed accounts.
Manulife uses an independent third party to maintain an exclusion list of companies that manufacture cluster munitions. The exclusion list is updated on a quarterly basis.