MNUFF Manulife Financial Corporation (PK)

Description of Exhibit

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Main Sections of the Code

Our Values

Why Ethics Matter

Ethics in The Workplace

Ethics in Your Business Relationships

Conflicts of Interest

Handling Information

Ethics and The Law

A Final Word

Promoting Equal Opportunity

Treat Others with Respect and Exercise Professionalism

Keep Your Workplace Safe

Keep Your Workplace Secure

Freedom of Association

Human Rights

Human Trafficking and Slavery

Expectations Relating to Business Partners

6

Why Ethics Matter to You and the Company

The Purpose of this Code

Application of the Code

Conflicts of Interest and Ethics

What if Someone Violates the Code?

12

Ethics in Your Business Relationships

Protect and Enhance the Company’s Reputation

Treat Others Honestly and Fairly

Take Care in Government and Political Dealings

Working with Industry Groups and Others

Where to Go for Help

Overview

Manulife’s Commitment to Ethical Conduct.

The Manulife Financial Corporation (Manulife) 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. It is the obligation of all of us to comply with the Code. In addition, it is each employee’s responsibility to identify, disclose and avoid potential or actual conflicts of interest.

Become Familiar with the Code. We must all be thoroughly familiar with its provisions and conduct ourselves according to both the letter and the spirit of the Code. With a long tradition of uncompromising dedication to the highest standards of business conduct, Manulife enjoys a reputation of unquestioned integrity and honesty. This reputation is among our most valuable assets, and we must protect it.

Code Guidance is Principles-Based. The Code is meant to provide principles-based guidance for our daily conduct at work. It is not meant to be a compendium of all rules or of all Manulife policies that govern our behaviour. Nevertheless, specific provisions are included to help illustrate certain principles and to address general governance needs where necessary.

Code Governance and Oversight. The Code is reviewed annually, with input from colleagues across functions. The Global

Chief Compliance Officer and General Counsel have oversight of the Code and the Code is reviewed and approved annually by Manulife’s Board of Directors.

For purposes of this Code, the “Company” or “Manulife” means Manulife Financial Corporation and its subsidiaries.

Why Ethics Matter

At Manulife, we value our good name and strive to maintain high standards of integrity in everything we do.

Why Ethics Matter to You and the Company

Acting Ethically is Always the Right Thing to Do. First and foremost, acting ethically is always the right thing to do. Second, operating in an ethical manner is essential to our success. Our customers, investors, employees, and other stakeholders rely on us to be honest and fair. We must behave ethically in the communities where we operate in order to maintain the confidence of all our stakeholders and ultimately to keep their business. It is in our best interest to set high standards for ourselves at all times and to align ourselves with agents, representatives, suppliers and business associates who have similar high standards of business conduct.

The Purpose of this Code

Standards for Ethical Behaviour.

This Code provides standards for ethical behaviour when representing the Company and when dealing with customers, investors, employees, contingent workers, field representatives, external suppliers, competitors, government authorities and the public.

Application of the Code

Directors, Officers, Employees and Others Expected to Follow the Code.

Manulife’s Code of Business Conduct and Ethics applies to directors, officers and employees of Manulife and its

subsidiaries. Sales representatives, third party business associates, contractors, agents and all individuals with certain duties and obligations to the Company are also expected to abide by all applicable provisions of the Code and adhere to the principles and values set out in the Code when representing Manulife to the public or performing services for, or on behalf of, Manulife. This Code is available on the Company’s website, on MFCentral and is also available in print upon request.

Conflicts of Interest and Ethics

Actual Personal Conflicts of Interest Are Not Waived, Potential Conflicts May Be Managed. Manulife does not waive actual conflicts of interest under any circumstances. Any potential conflicts of interest, including but not limited to the appearance of a conflict of interest, must be managed to preclude the potential conflict of interest from becoming an actual conflict of interest. It is the duty of each of us – Officers, Directors, employees and contingent workers – to identify and avoid any conflicts of interest. Typical controls include clear and complete disclosure of the potential conflict of interest to Compliance and recusal from any decision-making relating to the situation giving rise to the potential conflict of interest. Failure to meet this standard may result in discipline up to and including termination of any relationship with the Company.

Other Policies to Consult and Follow. At the end of each section is a list of related Company policies you should refer to for more information. These Company policies should be consulted to determine their applicability to any given Segment, subsidiary, or affiliate.

Waivers for Some Very Limited Exceptional Circumstances Only. Like the prohibition on actual conflicts of interest, certain additional provisions of this Code may never be waived; for example, the duty to always act in an ethical manner. With the exception of actual conflicts of interest, waivers to any part of the Code, while unusual, may only be granted in exceptional circumstances. For employees below the level of Vice President, such waivers may only be granted with the explicit written approval of the Global Chief Compliance Officer. For directors and employees at the level of Vice President and above, any such waiver will be granted only upon approval by the Manulife Board of Directors or Board Committee and will be disclosed promptly as required by law or stock exchange regulation.

What if Someone Violates the Code?

Consequences for Violating the Code.

All our activities must be able to withstand close scrutiny. To protect Manulife’s good name, the Company may discipline and/or terminate its relationship or affiliation

with any director, officer, employee, contingent worker, representative, associate, or supplier who breaches this Code or any related Company policy. If violating the Code also violates the law, you may also be subject to prosecution.

Referring Matters to Law Enforcement, Regulators or Others. Unless prohibited under local law, where the Company has reason to believe that an individual’s violation of the Code constitutes criminal conduct, Manulife may, in addition to terminating the individual’s relationship with Manulife (e.g., an individual’s employment or engagement with Manulife) without notice, refer the matter to law enforcement, disclose the matter to a regulator or self-regulatory organization and disclose (internally and/or externally) relevant facts underlying the conduct and the Company’s remedial measures.

Where to Go for Help

Ask First, Act Later. It is critical that all of us who represent Manulife and its subsidiaries use good judgment and common sense. It is the best way to ensure that our Company continues to meet high standards of business conduct. Since we cannot anticipate every situation

that will arise, it is important that we have a way to approach questions and concerns. If you are unsure of what to do in any situation, seek guidance before you act. Always ask first, act later.

Retaliation for Good Faith Reports of Illegal or Unethical Behaviour Strictly Prohibited. You may report suspected or potential illegal or unethical behaviour without fear of retaliation. The Company absolutely prohibits retaliation of any kind for good faith reports of illegal or unethical behaviour.

Presumption of Good Faith Reporting. All reports are presumed to be made in good faith. No report will be found to have been made in bad faith without clear and convincing evidence of bad faith.

When to Speak Up and With Whom.

Speak to your manager, your Segment Chief Compliance Officer, a member of the Law Department or a member of the Human Resources Department if you have:

•  Doubts about a particular situation;

•  Questions or concerns about a business practice;

•  Questions about potential conflicts of interest or the appearance thereof; or

•  Concerns about potential or suspected illegal, unprofessional, fraudulent or other unethical behaviour.

•  Threats stemming from suspected undue influence, foreign interference and malicious activity, defined as:

¤   Undue influence includes situations where a person or entity engages, with malicious intent, in actions, behaviours, deception or

   the use of power to impact actions, decisions, or behaviours in their own or another’s interests. Undue influence can originate from foreign or domestic actors and may have national security implications.

¤   Foreign interference includes activities that are within or relating to Canada, detrimental to the interests and security of Canada, and are clandestine or deceptive or involve a threat to any person, including attempts to covertly influence, intimidate, manipulate, interfere, corrupt, or discredit individuals, organizations, and governments to further the interests of a foreign state-or-non-state actor.

¤   Malicious activity includes actions taken with the intent of causing harm including theft, coercion, fraud, manipulation of information or disruptions that are otherwise illegal, malicious, clandestine, or deceptive in nature. Malicious activity can originate from foreign or domestic actors and may have national security implications.

Escalation Point for Hotline Matters Not Addressed. If you feel that your questions or concerns have not been appropriately addressed, you should direct your complaint to the Manulife Global Chief Compliance Officer or the Manulife General Counsel, whose contact information is available on MFCentral.

Who Can Use the Hotline. While the Ethics Hotline is intended primarily for the use of employees, third parties (e.g., shareholders, vendors, suppliers, sub-advisers, etc.) may also report suspected unethical, unprofessional, illegal, or fraudulent activity. Concerns received

via the Ethics Hotline related to auditing or accounting matters will be forwarded to Manulife’s Audit Committee by the Global Chief Compliance Officer.

Board Governance and Independence. Members of Manulife’s Board of Directors should direct any questions or concerns about the scope or applicability of this Code to the Manulife General Counsel. In addition, to maintain the independence of Manulife’s Board of Directors, the Board and its committees may retain outside advisors as they deem necessary. Individual Manulife directors may also retain outside advisors, at the Company’s expense, to provide advice on any matter before the Board or a Board Committee with prior approval from the Manulife Corporate Governance & Nominating Committee.

Guidance for Non-Management Directors of Manulife Subsidiaries. Non-management directors of Manulife subsidiaries should direct any questions or concerns regarding this Code, its scope or its applicability to the General Counsel, or to the person holding a similar position, for the entity on whose Board they serve.

Quick Ethics Check

rules, it cannot cover every situation. Ethics sometimes come down to a personal decision. To help you make the right choice, ask yourself the following questions:

•  Is this legal?

•  Is it fair?

•  Would I want other people to know I did it?

•  How would I feel if I read about it in the newspaper?

•  How will I feel about myself if I do it?

•  What would I tell a family member or a close friend to do in a similar situation?

Our Values

Values are the guiding principles that represent how we operate and help us define how we work together. They inform our actions and how we interact with each other and our customers.

•  Obsess about customers

•  Do the right thing

•  Think big

•  Get it done together

•  Own it

•  Share your humanity

Promoting Equal Opportunity

Diversity, Equity, and Inclusion at Manulife. At Manulife, we embrace our diversity and treat all individuals with dignity. We strive to attract, develop, and retain a workforce that is as diverse as the customers we serve and to foster an inclusive work environment that embraces the strength of cultures and individuals. We are committed to fair recruitment, retention, advancement and compensation, and we administer all of our practices and programs without discrimination on the basis of race, ancestry, place of origin, colour, ethnic origin, citizenship, religion or religious beliefs, creed, sex (including pregnancy and pregnancy-related conditions), sexual orientation, genetic characteristics, veteran status, gender identity, gender expression, age, marital status, family status, disability, or any other ground protected by applicable law.

Treat Others with Respect and Exercise Professionalism

Respect and Professionalism in the Workplace. We must give co-workers the same respect and service we give customers, and the same respect we expect for ourselves. When we communicate with each other within the organization, we must be open, honest, respectful, and professional. It’s one way to ensure quality in everything we do.

Behave Professionally. It is important to behave responsibly and professionally in the workplace at all times. It is also important to behave responsibly and professionally when representing Manulife or attending Company events, as well as when dealing with clients, potential clients and in all business activities.

Discrimination, Harassment, and Violence in the Workplace are Strictly Prohibited. The Company strictly prohibits discrimination, harassment and violence in the workplace. If you experience or observe this behaviour you should report it to your Human Resources Partner, Employee Relations, your manager, your Segment Compliance Officer, a member of the Law Department or the Ethics Hotline. In short, if you see something, report it. The Company absolutely prohibits retaliation of any kind for good faith reports of illegal or unethical behavior.

For more guidance refer to the Discrimination, Harassment and Workplace Violence Policy.

Quick Professionalism Check

Professionalism means conducting oneself with responsibility, integrity,

accountability and excellence. Often, professionalism requires a level of judgement. If you’re facing a situation where you’re not sure what course of action professionalism requires, ask yourself the following questions:

•  Could someone reasonably perceive this as being unprofessional?

•  Will others be upset or offended by this conduct?

•  Am I taking into consideration how others will respond?

•  Would I want other people to know I did it?

•  How would I feel if I told a family member that I did this?

Keep Your Workplace Safe

A Safe and Healthy Work Environment for All. Manulife provides a safe and healthy work environment for all employees.

Ethics in Your Business Relationships

Our business depends on sound relationships with customers, the community, other organizations, and our stakeholders.

We maintain these relationships by taking extra care when giving or receiving gifts, when producing materials for customers and others and when sharing information with outside individuals and organizations.

Protect and Enhance the Company’s Reputation

Protecting the Company’s Reputation. All individuals to whom this Code applies must conduct their business activities in a manner that protects and enhances the Company’s reputation. The risk of damage to our reputation must be a key consideration in assessing and engaging in any business relationship, transaction or activity. Any incident with the potential to harm our reputation is of high priority and senior management is to be alerted.

Treat Others Honestly and Fairly

High Standards of Honesty, Fairness and Courtesy. We believe embedding a strong risk culture and fostering ethical conduct across Manulife is essential to uphold our reputation and the trust of our customers. Our commitment to treating customers fairly and ensuring good customer interactions and outcomes extends across the business lifecycle, including product development, distribution, claims, addressing complaints, investigating potential misconduct and assessing product performance. We must treat customers with high standards of honesty, fairness, and courtesy. Customers must be able to voice their concerns easily,

and we must deal with complaints and disputes fairly and quickly. The materials we provide to customers, investors and other stakeholders must meet high standards of professionalism. Advertising and sales materials must be factual, easy to understand and based on the principles of fair dealing and good faith. All promotional efforts, illustrations of products and marketing concepts must be factual. We must provide accurate, factual, and clear information that is not misleading to customers, investors or other stakeholders.

Guidance on Conduct Risk. For more guidance, refer to Manulife’s Conduct Risk Framework.

Guidance on Company Materials. We seek competitive advantage through superior performance, never through unethical or illegal business practices.

In short, we seek to outperform our competitors fairly and honestly. The materials we provide to customers, investors and other stakeholders must meet high standards of professionalism. Advertising and sales materials must be factual, easy to understand and based on the principles of fair dealing and good faith. All promotional efforts, illustrations of products and marketing concepts must be factual.

Additional Guidance. We must be careful not to mislead customers, investors or other stakeholders about the financial status, products or services of the Company or

Conflicts of Interest

Conflicts of Interest Defined. A conflict of interest occurs when your individual or an organizational interest interferes in any way with the interests of the Company, its clients or its customers.

In addition to being the right thing to do, in certain business lines, such as Manulife’s Global Wealth and Asset Management Segment, Manulife businesses may have an explicit fiduciary obligation (sometimes referred to as a “duty of care”) to put their client’s interests ahead of its own. A conflict situation can arise when you take actions, have interests, or are involved in outside activities that make it difficult to perform Company work objectively and effectively, or affect your judgment to act in the best interest of customers, investors and other stakeholders.

Organizational Conflicts May Be Managed; Personal Conflicts Are Prohibited. Conflicts can also take on different forms depending upon the context in which they arise. The two main forms we see in most contexts are: organizational conflicts of interest and personal conflicts of interest.

Actual Personal Conflicts of Interest are Prohibited. Manulife strictly prohibits actual personal conflicts of interest. Unlike actual personal conflicts of interest, organizational conflicts of interest can be addressed through a variety of means including full and proper disclosure, the implementation of mitigating controls or the avoidance of the conflict altogether.

members must not receive money or any item of value, including the promise of employment or future business from any third party in connection with the officer’s or employee’s participation in any Company transaction. Officer compensation, other than Company wages, bonus, pension or benefits, may be regulated by law and requires approval by a Segment Head.

Additional Rules for Company Officers to Follow. Company officers may not have any interest in commissions or other compensation based on premiums or consideration payable to the Company on any policy or contract of insurance unless the policy or contract was written and effective prior to the officer’s appointment. In addition to the rules noted below, a director, officer, or employee may not give or receive any gift or form of gift, gratuity, or entertainment to or from anyone with whom the Company has, or is likely to have, any business dealings, if the gift or entertainment could reasonably be perceived as an attempt to influence the recipient’s judgment. For example, a director, officer, or employee should never solicit a gift, gratuity or shared business entertainment from a current or prospective business partner or client in exchange for a certain outcome or in circumstances where the director’s, officer’s or employee’s judgment may appear to be influenced. This also applies to charitable donations of any kind. Any charitable donations made by current or prospective business partners or clients must be appropriate.

Suitability of Gifts, Gratuities, Charitable Contributions or Entertainment. If the suitability of a gift, gratuity, charitable contribution, or entertainment is questionable, employees must consult with their Segment Chief Compliance Officer and/or Legal Officer. After escalation to the Segment Chief Legal Officer, if there is any remaining concern about whether the gift or expenditure is allowed under the Code, the matter must be escalated to the Global Chief

Compliance Officer. Additionally, Manulife directors should forward inquiries to the Manulife General Counsel. Non- management directors of Manulife’s subsidiaries should consult with the entity’s General Counsel or person holding a similar position.

Guidance on Shared Business

Entertainment. Shared business entertainment in the form of attendance at ticketed sporting and entertainment events should be limited to one event per year, per business partner. Extra caution must be exercised for exclusive and premier entertainment events of any kind. In certain cases, attendance at high-value ticketed sporting and entertainment events for legitimate business purposes may be considered with reimbursement to the donor. For more guidance, please reach out to the Compliance Office.

Public Officials. Gifts, gratuities, or entertainment provided to public officials, including employees of state-owned enterprises and political parties, are covered in the section titled “Take Care in Government and Political Dealings.”

Insurance Customers or Prospects. In many of the jurisdictions we operate in, gifts or entertainment, including promotional items, are subject to insurance anti-rebating and inducement laws governing the sale of insurance and annuity products. Questions regarding the application of these laws should be directed to your Segment Compliance Officer.

Sales and Related Activities. Specialized rules and regulations apply to sales activities in many of the jurisdictions we operate in. For example, in the U.S., FINRA rules govern the receipt and giving of gifts involving registered representatives or broker-dealers. Questions regarding the applicability of these sales-related rules and regulations should be directed to your Segment Compliance Officer.

Dealing with the External Auditor. No employee of Manulife should give to or receive from the External Auditors any gifts or things of value. Additional guidance is outlined in a memorandum from the Chief Financial Officer dated March 15, 2021.

Be Careful about Personal Benefits

Personal Benefits to You or Your Family Member Can Create a Conflict of Interest. Conflicts of interest may arise if you or your family member receive a personal benefit as a result of your position in the Company. All such personal benefits, including loans and guarantees of obligations from the Company, must be disclosed on the Company’s Code of Business Conduct and Ethics Certification and Conflict of Interest Disclosure Questionnaire and approved by the Company. Personal loans to executive officers are prohibited unless specifically permitted by law.

Involvement in Investment Decisions Requiring Disclosure. Manulife directors, officers and employees shall not recommend or participate in any Company investment decision involving an entity in which they or any of their family members have a financial interest, unless the existence of such interest has been properly disclosed to a supervisor in their reporting chain, who must be at least AVP level, and to all those involved in all stages of the investment approval process. In addition, as with any other potential conflict of interest, the supervisor must consult with relevant compliance personnel in their Segment and determine that there is no actual conflict of interest. Manulife directors and corporate officers should also review Manulife’s Conflict of Interest Rules for Directors and Officers.

Giving in an Ethical Manner

Charitable Contributions Evaluated under

Community Investment Standard. Investing in the communities we serve is an important way we drive social impact. In addition to meeting the requirements outlined elsewhere

in the Code, all Community Investment contributions to charitable, non-profit or similar organizations are reviewed to help ensure they align with our values.

Invest in an Ethical Manner

Trading Manulife Securities while in Possession of MNP Prohibited. Directors, officers and employees must strictly follow all laws and regulations affecting investments. It is unethical and illegal for directors, officers and employees to buy or sell Manulife securities while in possession of material information that has not been publicly disclosed about the Company or to inform another person, except as permitted by law, of material information that has not been publicly disclosed.

In addition, it is unethical and may be illegal to buy or sell securities of another company with the benefit of your knowledge of the Company’s investment intentions or any material information that has not been publicly disclosed about that company.

Beware of Conflicts of Interest when Investing. Directors, officers and employees must also be cautious of potentially being in a conflict of interest where they wish to make an investment in a business entity which they know transacts business with Manulife or in which Manulife has made an investment.

Do Not Speculate in Manulife Securities.

In order to comply with applicable laws and to ensure that perceptions of improper insider trading do not arise, Manulife prohibits its directors, officers and employees from speculating in Manulife securities. Speculation includes the purchase or sale of Manulife securities with the intent of reselling or buying back in a relatively short period of time, with the expectation of a rise or fall in the market price of such securities, the buying or selling of derivatives such as put or call options on Manulife securities and short selling Manulife securities.

Additional Guidance Related to the Insurance Companies Act (Canada). Furthermore, directors, officers and insiders of the Company who directly or indirectly short sell Manulife securities or buy or sell put or call options or other derivatives on Manulife securities may be liable, pursuant to the provisions of the Insurance Companies Act (Canada), to compensate persons who suffered a loss and to compensate the Company for any benefit or advantage received because of the transaction.

Monetization of Equity Awards Before Vesting and Payment is Prohibited. The monetization of equity awards before vesting and payment by the Company is prohibited.

Refer to Manulife’s Insider Trading Policy for More Information. For further questions relating to the handling of inside information and/or the trading of Company securities or derivatives, you should refer to Manulife’s Insider Trading and Reporting Policy.

Some Employees May Also Be Subject to Business-Level Code of Ethics. Additionally, as a global financial institution, government regulators, business partners and customers expect Manulife to adopt and enforce codes and standards to proactively address the conflicts between employee personal investing and the investment activities of our businesses. Thus, certain employees who are involved directly or indirectly in Manulife’s investment businesses or have access to certain sensitive investment information are required to comply with certain business-level codes of ethics.

Business-Level Codes of Ethics Apply to Employee and Members of Their Household. These business-level codes of ethics impose disclosure obligations and limit personal investment activities in Manulife and non-Manulife securities by both the employee and members of the employee’s household. These obligations and limitations include but are not limited to: obtaining Manulife approval

for certain personal securities transactions, providing Manulife with access to personal securities holdings and transaction information, limitations on the use of certain brokerage firms and limitations on certain personal investment activities.

Working for Competitors May Jeopardize the Company

Working for a Competitor Prohibited. No

Manulife officer or employee may work for any organization that competes with the Company or enter into a relationship that creates a conflict of interest with the Company. This includes serving as a director, officer, trustee, partner, employee, consultant, or agent.

Report All Outside Employment or Business Activity to the Compliance Office. Employees must report all outside employment or business activity to the Compliance Office by submitting a Conflict of Interest Disclosure Questionnaire. Employees have a continuing obligation to update their Conflict of Interest Disclosure Questionnaire and submit it to the Compliance Office whenever circumstances change.

Guidance for Directors of Manulife or its Subsidiaries. Directors of Manulife or its subsidiaries will follow their own policies relating to outside business relationships.

External Directorships

Report All Prospective External

Directorships Prior to Accepting. Employees must report to the Compliance Office any external directorships they wish to accept. While many external directorships do not pose a conflict of interest and may not require approval, some external directorships could pose a potential conflict and/or will require approval. For that reason, before accepting an external directorship, employees must report a prospective directorship to the Compliance Office for review. The requirement to obtain prior approval before accepting any

external directorship includes directorships on charitable boards.

External Directorships Reviewed for

Potential Conflicts of Interest. The Compliance function reviews all prospective directorships to confirm that the directorship does not pose a conflict of interest, and to confirm that appropriate approvals are obtained up to and including Executive Leadership Team approval.

Guidance on External Public Directorships.

Because of the unique issues relating to serving on a publicly traded company, employees are generally not allowed to serve as directors on boards of publicly traded companies. For additional guidance, please refer to the External Directorships Standard.

Use Caution Regarding Outside Positions

Outside Positions Cannot Hamper Your Performance, Judgment or Create a Conflict of Interest. Outside work or financial involvement in external organizations can lead to conflicts of interest, which could interfere with your ability to give objective, full-time attention to your work with Manulife or could damage the Company’s reputation. Subject to applicable law, you must not engage in any other employment or take any civic, charitable, government or political position that would hamper your performance or your judgment to act in the Company’s best interest or that would create a conflict of interest. You have a continuing obligation to update your Conflict of Interest Disclosure Questionnaire and submit it to the Compliance Office whenever your circumstances change.

Protect Corporate Opportunities

Protecting Corporate Opportunities.

Individuals to whom this Code applies are prohibited from: to whom this Code applies are prohibited from: (a) benefiting from opportunities that are discovered through the use of Company property, information or position; (b) using Company property, information or position for personal gain; and (c) competing with the Company during the term of their relationship with the Company. You owe a duty to the Company to advance its legitimate interests when the opportunity to do so arises.

Protect the Company’s Name, Reputation and Assets

Company Name Used for Authorized Company Business Only. The name “Manulife” must be used only for authorized Company business and never for personal activities. Do not identify yourself with the Company while pursuing personal, political, or not-for-profit activities, unless you obtain prior approval from the Chief Compliance Officer in your Segment.

Statements About the Company Must be Honest and Accurate. An important way to protect the Company’s reputation is to always be honest and accurate when making statements when discussing the Company. False information or statements about the Company, its representatives, employees, products, or services can damage the Company’s reputation. You must not make false written or oral statements about the Company, its employees or representatives or its products and services in print, via electronic media or in person.

Guidance for Those with Access or Control

Over Company Transactions and Assets.

Each director, officer, employee, representative or other associate entrusted with access to or control over Company transactions and assets

Ethics and the Law

Consequences for Potential Criminal Conduct.

Manulife is committed to operating within the laws and regulations of every jurisdiction in which it operates. If an intentional violation of the Code also involves potential criminal conduct, unless prohibited under local law, Manulife may, in addition to terminating an individual’s relationship with the Company without notice, refer the matter to law enforcement, disclose the matter to a regulator or self-regulatory organization and disclose (internal and/or external) relevant facts underlying the conduct and the Company’s remedial measures.

Know and Comply with the Law

Know and Follow the Laws that Affect Your Work. You are required to understand the laws that affect your work and make sure your business conduct complies with those laws. You must promptly report violations and always act in accordance with this Code and other applicable Company policies.

Manulife’s Compliance Management Program. A formal compliance management program is in place at Manulife. It is designed to promote consistent management and monitoring of compliance with laws and regulations in all Company operations. If you have questions or concerns relating to compliance, consult the procedures described in the section of this Code titled “Where to go for help.”

Membership in a Professional Association. If you belong to a professional association, you are also expected to abide by that association’s governing rules of professional responsibility and conduct in the performance of your job.

Manage Assets Properly

Customer Funds Handled in a Trustworthy Manner. Customers expect that the money they entrust to the Company will be handled responsibly. If you have access to customer funds, you must make sure customer funds are handled in a trustworthy manner. Every Segment has procedures and standards to help protect and account for all funds under management and to prevent carelessness, fraud, or dishonesty.

Identify and Report Fraud and Theft

Be Aware: Fraud Takes Many Forms. As a provider of financial services, Manulife is vulnerable to losses from dishonesty and fraud. Fraud can take many forms, such as mishandling of money, theft of cash or property, money laundering, corrupt payments of money and provision of things of value, terrorist financing, misrepresentation and falsification or forgery of documents.

Duty to Report Any Suspicious Activity. Dishonest activities, combining personal and business funds and fraud are all illegal. It is management’s responsibility to ensure there are proper internal controls to deter and detect fraud and other dishonest activities, but everyone in the Company must help, including by following internal controls. If you are aware of any suspicious activity, you have a duty to report it immediately to the relevant immediate supervisor, Compliance, or via the Ethics Hotline. Furthermore, you have a duty to fully and truthfully cooperate with any investigations pertaining to Company matters.

Reminder: Reporting Any Illegal or Unethical Behaviour

Duty to Report. You have a duty to report suspected or potential illegal or unethical behaviour and to seek input when you are in doubt about the best course of action in a particular situation. Consult the procedures described in the section of this Code titled “Where to go for help” on reporting any suspected or potential illegal or unethical behaviour.

The Company Prohibits Retaliation for Good Faith Reports. As outlined above, you may report suspected or potential illegal or unethical behaviour without fear of retaliation. The Company absolutely prohibits retaliation of any kind for good faith reports of suspected or potential illegal or unethical behavior. In addition, directors, officers, employees, representatives, agents and other associates are expected to fully and truthfully cooperate in internal investigations of alleged misconduct.

A Final Word

Manulife’s reputation is the result of more than 130 years of dedication, quality service and ethical dealings. Keeping our good reputation depends directly on the decisions you make every day.

This Code of Business Conduct and Ethics provides standards and sets high expectations for directors, officers, employees, representatives, suppliers and other associates, as well as those providing services to the Company. Subject to the approval of the MFC Audit Committee, the Company may modify the Code at any time, as appropriate.

However, as emphasized in the Code, your own good judgment is most important in ensuring that Manulife remains an ethical company.

Other Policies

The Company has related policies to help you deal with ethical issues, including on topics related to Anti-Fraud, Anti-Money Laundering and Anti-Terrorist Financing, Information Security, Privacy, Social Media, Reputation Risk, Conduct Risk, Insider Trading and Reporting, among others. Segments may also maintain Segment-level policies or standards.

Company policies can be found in the Company Global Policy Database.

Clawback Policy. Finally, please also note that all executives at the Vice President level and above are required to comply with the clawback policy, under which the Board has the discretion to

cancel unvested incentive awards and/ or clawback vested and/or paid incentive awards, as applicable, in the event of your fraud, theft, embezzlement or serious misconduct (which includes, but is not limited to, dishonesty or a breach of company policy to the material detriment of Manulife’s or John Hancock’s business or reputation and any conduct that would qualify as cause for termination of employment at common law) irrespective of whether there was a financial restatement. In this paragraph, “incentive awards” include vested, unvested and/or paid AIP payments, RSUs, PSUs, DSUs and/or Stock Options.

Further Helpful Information

If you wish to ask questions about the Code or report suspected misconduct, you may reach out or raise your concerns to your manager, Legal, Compliance, your Human Resources Partner or Employee Relations and for those seeking to remain anonymous, you may contact Manulife’s Ethics Hotline. Manulife’s Ethics Hotline is available 24-hours per day, seven days per week. You may report suspected or potential illegal or unethical behaviour without any fear of retaliation.

Contact the hotline at: www.manulifeethics.com or 866-294-9534.

If you have a question or concern, you may contact the Compliance Office at:

GlobalComplianceOffice@manulife.com

or the following Compliance Office staff:

Sören Seitz

Global Chief Compliance Officer

Soeren_Seitz@manulife.com

Kevin Askew

Global Chief Financial Crimes and Anti-Money Laundering Officer

KAskew@jhancock.com

Tiff Palmer

VP & Chief Ethics Officer

Tiffany Palmer@manulife.com

Robin Pak

AVP & Senior Counsel

RobinPak@jhancock.com

Christine Au-Yeung

Director, Ethics Office

Christine_Au-Yeung@jhancock.com