CANADIAN IMPERIAL BANK OF COMMERCE /CAN/

Ensuring the effectiveness of our Code

Each year, all employees and contingent workers must complete mandatory training and testing, and attest that they have read, understood, and continually abide by our Code. CIBC Board members are also required to certify to their compliance with our Code.

Did you know? CIBC’s mandatory training program protects our bank from legal, reputational, and financial risks, and includes topics such as our Code, anti-money laundering and anti-terrorist financing, managing risk, preventing and detecting fraud, protecting information, maintaining a respectful and safe workplace, as well as other region and business-specific training. We can access our mandatory training and testing - and other helpful training and resources - at any point in the year to refresh our learning.

1* Frameworks, Policies, and other related supporting document types, including but not limited to guidelines, processes, procedures and standards, are referred to as policies throughout our Code.*

2The CIBC Code of Conduct is applicable to all team members of CIBC and its wholly-owned subsidiaries, except for team members in CIBC Cayman Bank Limited and CIBC Cayman Reinsurance Limited) which have their own codes of conduct to comply with local requirements.

Key contacts and resources - including global and regional policies - are referenced throughout our Code. If anything is unclear, or if we have any questions, we will contact our people leaders, another appropriate contact listed within our Code, or our Code of Conduct, Mailbox.

We also have mechanisms in place to detect and identify potential violations of our Code, including internal controls, robust monitoring processes, and comprehensive reporting. When potential violations of our Code are detected or identified, they are reviewed through the appropriate channels, in accordance with applicable laws and CIBC policies, to determine outcomes and consequences.

A contravention of our Code is a serious matter and may give rise to consequences. An employee who contravenes any provision of our Code may be subject to disciplinary action up to and including termination of employment for cause without notice, or pay in lieu of notice, as well as possible civil, criminal, or regulatory action. Such conduct may also affect their individual performance assessments and compensation. A contingent worker who contravenes any provision of our Code applicable to contingent workers may be subject to action by CIBC up to and including termination of their assignment without notice, as well as possible civil, criminal, or regulatory action.

We use insights and trends to improve our Code and ensure it remains clear and practical. As part of these monitoring and reporting processes, we regularly report to the Board of Directors on violations of our Code, as well as conduct and culture risk and key regulatory developments.