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CANADIAN IMPERIAL BANK OF COMMERCE /CAN/

For the period ended Oct 31, 2024. Filed Dec 5, 2024.

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About this filing

The yearly report of certain Canadian companies, filed under a joint US and Canadian system. It is the main yearly account these companies give US investors, largely as filed in Canada.

FY2024 · Filed Dec 5, 2024

Use the contents to explore the available documents and sections.

CM$115.18-0.4%Stored close · as of Nov 6, 2026
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Contents

CODE OF ETHICS

CIBC has adopted a Code of Conduct applicable to all its officers (including CIBC’s Chief Executive Officer, Chief Financial Officer, Chief Accountant and Controller), directors, employees and contractors. The Code of Conduct meets the definition of a “code of ethics” (as that term is defined in General Instruction B(9)(b) of the General Instructions to

Form 40-F).

The Code of Conduct is available on CIBC’s website at

https://www.cibc.com/ca/inside-cibc/governance/governance-practices/code-of-conduct.html

. CIBC also undertakes to provide a copy of the Code of Conduct to any person without charge by contacting Investor Relations at investorrelations@cibc.com or by mail “Attention: CIBC Investor Relations” at the Toronto executive office address shown above.

Effective November 1, 2024, in addition to certain other technical, administrative or

non-substantive

revisions, CIBC adopted the following amendments to the Code of Conduct:

•Introduced a decision framework to help team members think critically and use appropriate judgment.
•Separated the contents in 2.1 We comply with the law and CIBC policies into distinct subsections: 2.1 We comply with the law and regulatory requirements, 2.2 We adhere to CIBC policies, guidelines, and processes, and 2.5 We know our clients and provide appropriate advice.
•Strengthened content related to discrimination and protected characteristics.
•Separated the contents in 6.1 We protect confidentiality and privacy into distinct subsections: 5.1 We protect the privacy of our clients and team members and 5.2 We safeguard confidentiality and CIBC’s information security and property.

No waivers from the provisions of the Code of Conduct were granted in the fiscal year ended October 31, 2024 to the Chief Executive Officer, Chief Financial Officer, Chief Accountant or Controller of CIBC.

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The text of this filing, as the company filed it with the SEC, without its images or exhibits. This is not investment advice.