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CANADIAN IMPERIAL BANK OF COMMERCE /CAN/

For the period ended Oct 31, 2025. Filed Dec 4, 2025.

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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.

FY2025 · Filed Dec 4, 2025

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, 2025, in addition to certain other technical, administrative or

non-substantive

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

•Entire document: Editorial changes throughout to improve clarity, readability, and allow for better identification of trends and remedial strategies.
•Section 2: Strengthened to include reference to CIBC’s Integrity and Security Framework to align with requirements set out in OSFI’s Integrity and Security Guideline.
•Section 3: Enhanced language regarding identifying and avoiding conflicts of interest, including when processing personal transactions.
•Section 5: Added a subsection focusing on the safe and responsible use of Artificial Intelligence (AI), including reference to CIBC’s Trustworthy AI Principles.

No waivers from the provisions of the Code of Conduct were granted in the fiscal year ended October 31, 2025 to the Chief Executive Officer, Chief Financial Officer, Chief Accountant or Controller of CIBC.

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