The ethics hotline is a phone and web-based communications tool that offers Manulife/ John Hancock employees a confidential way to report suspected unethical, unprofessional, illegal or fraudulent activity conducted by others associated with the Company. All information is kept confidential and all reports will be taken seriously. Telephone and web reporters may remain anonymous. The Company strongly encourages employees to attempt to resolve issues through their management before using the ethics hotline. The ethics hotline is not intended for reporting questions or concerns regarding performance, discipline, and human resources policies on such issues as dress code violations, personality conflicts and disputes between employees that would not be considered fraudulent conduct. However, if an employee does not feel comfortable talking to their manager and/or Human Resources, they may report the matter to the ethics hotline. While the ethics hotline is intended primarily for the use of employees, third-parties (e.g., vendors, suppliers, sub-advisers, etc.) may also report suspected unethical, unprofessional, illegal or fraudulent activity.

No. The ethics hotline is primarily intended for the use of Manulife employees. Any customer concerns should be directed to the appropriate customer service or compliance unit.

An ethics hotline has been and continues to be one part of the Company’s overall mission to conduct business according to the highest standards of honesty and fairness. The use of a hotline is another tool employees may use to help us achieve this goal. The Company strongly encourages employees to attempt to resolve issues through their management before using the ethics hotline.

EthicsPoint is a solution provided by NAVEX, an independent company, that provides a comprehensive, secure and, if desired by the reporter, anonymous, telephone and web-based tool for reporting suspected unethical, unprofessional, illegal or fraudulent activity conducted by others associated with the Company.

The Privacy Statement for NAVEX appears at the lower right hand corner of the EthicsPoint webpage.

No. You may report suspected or potential illegal or unethical behaviour without fear of retaliation. Retaliation is prohibited under law and the Company's Code of Business Conduct and Ethics.

We certainly do. In fact, we need you to report. You may have initial knowledge of an activity that may be cause for concern. Your reporting can minimize the potential negative impact on the Company. Also, offering positive input may help identify issues that can improve the way we work.

EthicsPoint is a communications tool providing an avenue for sharing information of any kind that you regard as potential violations of Manulife’s Code of Business Conduct and Ethics. This may include concerns regarding unethical, unprofessional, illegal, fraudulent or other questionable behaviour including but not limited to:

• Accounting and auditing practices
• Confidentiality, privacy, and intellectual property
• Conflicts of interest
• Illegal or suspected illegal acts
• Reputational risk
• Unfair business practices or misrepresentation

The ethics hotline is not intended for reporting questions or concerns regarding performance, discipline, and human resources policies on such issues as dress code violations, personality conflicts and disputes between employees that would not be considered fraudulent conduct. However, if an employee does not feel comfortable talking to their manager and/or Human Resources, they may report the matter to the ethics hotline

Your questions or concerns regarding performance, discipline, harassment, discrimination and human resources policies may be addressed to your management, Employee Relations or Human Resources contact.

EthicsPoint does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to EthicsPoint is available. With fewer than 12% of reports generated during business hours, most people prefer to report from the comfort of their home after hours and on the weekend. Ethics Point is a third party service provider and is contractually obligated to not report any IP addresses.

The EthicsPoint system is designed to protect your anonymity. However, you as a reporting party need to ensure that the body of the report does not reveal your identity by accident, for example, “From my cube next to Jan Smith…” or “In my 33 years…”

File a report. EthicsPoint can help you prepare and file your report so it can be properly understood. We'd rather you reported a situation that turned out to be harmless than let possible unethical behavior go unchecked because you weren't sure. Please note, the hotline is not intended for reporting questions or concerns regarding performance, discipline, and human resources policies on such issues as dress code violations, personality conflicts and disputes between employees that would not be considered fraudulent conduct. However, if an employee does not feel comfortable talking to their manager and/or Human Resources, they may report the matter to the ethics hotline.

Reports are entered directly on the EthicsPoint secure server to prevent any possible breach in security. EthicsPoint makes these reports available only to specific individuals within the company who are charged with evaluating the type of violation and location of the incident. Each of these report recipients has had training in keeping these reports in confidence. The EthicsPoint system and staff are trained and committed to ensure that no report is ever shared with implicated parties, their peers, or subordinates.

Consistent with the admonition to avoid conflicts of interest which is set forth in Manulife’s Code of Business Conduct and Ethics (“A “conflict of interest” occurs when your private interest interferes in any way with the interest of the company” Code, p. 16, et. seq.), the Global Compliance Office takes all reasonable measures to help ensure that any EthicsPoint investigation and/or fact gathering process is conflict-free. By way of example, if a supervisor is named by a Reporter as the alleged subject engaged in the conduct complained of, then the supervisor shall not direct nor participate the investigation and/or fact gathering process, but the supervisor may be asked to submit to an interview and/or supply information.

Similarly, in the event that EthicsPoint allegations are lodged against the CEO, COO, the Global Compliance Chief, or all of the Global Compliance Office Level 1 Users of EthicsPoint, then the EthicsPoint system, pursuant to a set of instructions, shall refer such matters to a pre-defined set of designees to help ensure a conflict free investigation and/or fact gathering process.

When you file a report at the web site or via an international toll-free number, you receive a unique user name and are asked to choose a password. You can return to the EthicsPoint system again either by Internet or telephone and access the original report to answer questions posed by a company representative and add further information that will help resolve open issues. We strongly suggest that you return to the site in the time specified to answer company questions. You and the company now have entered into an “anonymous dialogue” where situations are not only identified but can be resolved, no matter how complex.

All EthicsPoint correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity.

There is a section in the report for identifying yourself, if you wish.

No. You may report suspected or potential illegal or unethical behaviour without fear of retaliation. Retaliation is prohibited under law and the Company's Code of Business Conduct and Ethics.

Yes you may. By giving you choices, EthicsPoint helps ensure that employees can file a report anonymously and in the manner most comfortable or convenient to them.

A report from home, a neighbor’s computer, or any Internet portal will remain secure and anonymous. An Internet portal never identifies a visitor by screen name and the EthicsPoint system strips away Internet addresses so that anonymity is totally maintained. Plus, EthicsPoint is contractually committed not to pursue a reporter’s identity. To report from outside the Company, simply go to www.ManulifeEthics.com.

You can file an EthicsPoint report from any computer that can access the Internet by going to www.ManulifeEthics.com. You can file from home. Many public locations, including the public library, have Internet computers. If you don’t have access or are uncomfortable using a computer, you can call the EthicsPoint toll free hotline which is available 24 hours a day, 365 days a year.

From Canada and the United States, dial toll free 866-294-9534.
From other countries, click here.

Yes. You will be asked to provide the same information that you would provide in an Internet-based report and an interviewer will type your responses into the web site. These reports have the same security and confidentiality measures applied to them during delivery.