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CIBC Code of Conduct - EXTERNAL

CIBC code of ConductNovember 2020 CIBC EXTERNAL Approved by CIBC s Board of Directors effective November 1, 2020 CIBC ExternalTable of ContentsA message from Victor G. Dodig, President and CEO ..41. Overview of the code .. What is the purpose of the code ? .. Who has to follow the code ? .. What do we expect of our people leaders? .. How should we use the code ? .. How do I speak up? .. What if I am concerned about retaliation for speaking up? .. What happens if I don t follow the code ?.. How does CIBC make sure the code is effective? ..72. We act with honesty and integrity .. We comply with the law and CIBC policies .. We prevent corruption, bribery, fraud and other financial crime .. We act within our scope of authority .. We act responsibly in managing inside information and our personal trading in securities.

6. Application of the Code. CIBC Code of Conduct – External. 1.5 . Annual Training and Certification. As part of CIBC’s Mandatory Training and Testing (CMTT) program,

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