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Table of Contents

1 Application of the Code

1.1 To Whom Does the Code Apply?

1.2 Application to CIBC Contractors

1.3 Your Role as a Manager

1.4 Ownership of the Code

1.5 Annual

Training and Certification

1.6 Exceptions to the Code

2 Acting with Honesty and Integrity

2.1 Ethical Behaviour

2.2 Upholding the Law

2.3 Rejecting Corruption and Bribery

2.4 Preventing Fraud

2.5 Acting Within Our Employment Duties and Delegated Authorities

2.6 Personal Trading in Securities and Managing Inside Information

2.7 Competing Fairly

2.8 Respecting Copyright

3 Treating Everyone with Respect

3.1 Protection Against Harassment and Discrimination

3.2 Safety and Security in the Workplace

3.3 Avoiding Alcohol and Drugs

3.4 Political or Religious Activity

Avoiding Conflicts of Interest

4.1 Offering

and Accepting Gifts or Other Benefits

4.2 Personal Borrowing and Lending

4.3 Treatment and Selection of Suppliers

4.4 Beneficiaries, Fiduciaries and Powers of Attorney

4.5 Engaging in Outside Activities and Investments

4.6 Processing Personal Transactions

5 Protecting Our Brand, Clients, Investors, Employees and the Environment

5.1 Representing CIBC

5.2 Community Activity

5.3 Full and Fair Disclosure

5.4 Guarding Against Misleading Marketing and Communication Materials

5.5 Environmental Responsibility

6 Our Role in Using and Safeguarding Information and Assets

6.1

Protecting Confidentiality and Privacy

6.2 Maintaining Information Security

6.3 Safeguarding CIBCs Assets

6.4 Following Business Expense Policies

6.5 Maintaining Records

7 Cooperating with Internal and Regulatory Investigations

8 Contravention of The Code

9 Seeking Advice

A Message from the CEO

November 2010

At CIBC, our reputation and our continued success depend upon a shared commitment to our core

values of trust, teamwork and accountability. Honouring this commitment is our first priority.

Living up to our values requires meeting the highest standards of ethical and professional

behaviour. The CIBC Code of Conduct (Code) sets out the principles and standards for ethical and

professional behaviour in everything we do.

As CIBC employees, we are required to know, understand and abide by the Code. This includes an

obligation to speak up if you become aware of any potential violation of the Code, talk to your

manager or get in touch with the appropriate contact listed in section 9 of the Code. If you report

an apparent violation of the Code in good faith, you can be assured that you will be protected from

any form of retaliation against you for doing so.

By embracing the Code, we honour our values, which helps CIBC achieve its vision of being the

leader in client relationships.

Sincerely,

Gerald T. McCaughey

President and CEO, CIBC

Living up to our values requires meeting the highest standards of ethical and professional

behaviour.

Application of the Code

1.1 To Whom Does the Code Apply?

The Code applies to all employees of Canadian Imperial Bank of Commerce and its wholly-owned

subsidiaries (collectively CIBC). This includes both regular and temporary employees working

either full- or part-time. The terms we and our as used in the Code refer to the shared

responsibility of all CIBC employees and are also meant to convey the fact that each of us has a

personal responsibility to uphold the principles of the Code.The Code represents the minimum

standards regarding our conduct and CIBCs obligations as a regulated financial institution.

Employees who are licensed by a regulatory or professional body are also expected to adhere to any

requirements imposed by those entities.

1.2 Application to CIBC Contractors

A number of sections in this Code offer protection to employees or require that we treat other

employees in a certain manner (see sections 3.1, 3.4, 5.1, 5.2, 6.1, and 8.0). In all of these

sections, CIBC Contractors, who are subject to a separate Contractor Code of Conduct, are also

entitled to receive this protection and treatment.

1.3 Your Role as a Manager

People managers play an important role in helping to ensure that the principles of the Code

are respected. They are the first point of contact for employees who have questions about the Code.

More importantly, managers are role models for employees regarding acceptable standards of

behaviour.

1.4 Ownership of the Code

The Chief Administrative Officer and General Counsel is Executive Owner of the Code. The Code

was approved by CIBCs Board of Directors and is reviewed annually. This version of the Code is

effective November 1, 2010.

1.5 Annual Training and Certification

As part of CIBCs Mandatory Training and Testing program, each of us will complete an annual

certification,

attesting to familiarity with and adherence to the principles of the Code and all of its

provisions.

Each individual has a personal responsibility to uphold the principles of the Code.

1.6 Exceptions to the Code

Some situations may warrant making exceptions to the Code. All requests for exceptions must be

discussed first with your manager. If your manager agrees to pursue the request, then written or

e-mail approval must be obtained from the Compliance Department.

Exceptions for certain executive officers may be granted only by the Board of Directors or by a

committee of the Board. Such exceptions must also be promptly disclosed to CIBCs shareholders.

Q What are some of the factors that may help me identify potential Code of Conduct issues?

To help identify Code of Conduct issues, ask yourself the following questions:

Is this legal?

Is this fair and ethical?

Would CIBCs reputation be harmed if this situation were to become public?

Might this situation create any conflict between my own interest and CIBCs interest? Might

it create the appearance of a conflict?

Does this feel right?

If in doubt, speak to your manager, call one of the contacts listed in section 9 of the Code, or

call the Ethics Hotline.

Q Where can I find more information about how to apply the Code?

Many sections of the Code include a link to related policies and procedures that provide detailed

guidance on specific topics.

Acting with Honesty and Integrity

2.1 Ethical Behaviour

Each of us has a fundamental obligation to act honestly and with integrity at all times. This

means respecting both the letter and the spirit of the Code in everything we do.

We must report any concerns relating to the honesty and integrity of CIBC, its employees, suppliers

or clients as set out in section 9 of the Code.

2.2 Upholding the Law

We are all required to uphold and comply with the law and any other requirements established

or endorsed by CIBC (including CIBC policies, procedures and standards, industry guidelines, and

the Code). Failing to do so risks exposing CIBC and/or its employees to serious regulatory

consequences and reputational harm.

Neither CIBC nor any of its employees may knowingly engage in, facilitate or benefit from any

illegal transaction or activity. Any employee who is charged with or found guilty of a criminal

offence must immediately notify his/her manager who, in turn, must notify Corporate Security.

2.3 Rejecting Corruption and Bribery

Achieving the highest standard of ethical behaviour means that we will not engage, directly or

indirectly, in bribery, kick-backs, payoffs or other fraudulent or corrupt business practices. If

we are approached by a supplier, client, government representative or other third party with an

opportunity to engage in such activity, we will report the incident to our manager, Corporate

Security or the Ethics Hotline.

2.4 Preventing Fraud

Successfully preventing fraud at CIBC requires an ongoing commitment from all of us. This

includes actively participating in the detection and reporting of suspected fraud, whether

committed by an employee or by a third party.

We must respect both the letter and the spirit of the Code in everything

we do.

2.5 Acting Within Our Employment Duties and Delegated Authorities

We are all accountable for acting within the scope of our employment duties and delegated

authorities. We must not:

give clients financial, trust, tax, investment, legal or other advice unless this is within

the scope of our employment duties and we hold the appropriate qualifications and licences to

do so;

act outside the scope permitted by our professional license, regulatory registration or

delegated authority; or

process a transaction, whether for a client or for CIBC, without proper authorization and

documentation.

Q What does it mean to respect the spirit of the Code?

Respecting the spirit of the Code means following the principles and values upon which the

Code is based acting ethically and professionally, and honouring our core values of trust,

teamwork and accountability even when the Code does not specifically address a particular

situation.

Q Many different laws apply to the work that I do. What should I do if Im not sure about

what these laws require?

Following CIBC policy and procedures and acting within the scope of your authority will help ensure

that you are complying with the law. If you are unsure about what you should do, always ask

questions before you act discuss the situation with your manager or with one of the contacts

listed in section 9 of the Code.

Q What are some examples of illegal activity?

Examples of illegal activity include, but are not limited to: fraud, theft, forgery, kiting,

money laundering, and bribery.

Q What is kiting?

Kiting is a form of fraud that involves depositing and drawing cheques between two or more

accounts at the same branch, at different branches, or at different financial institutions in order

to disguise lack of funds. It involves taking advantage of the float (the time between the

negotiation of the cheque and its clearance at the cheque-writers bank).

2.6 Personal Trading in Securities and Managing Inside Information

Each of us is responsible for knowing and strictly complying with the law applicable to the

handling of Inside Information. See the Q&A below for the definition of Inside Information.

Trading Securities

We must not trade in securities of a company if we have Inside Information about the company. In

addition, we will not advise others regarding trading in those circumstances.

We must ensure that, when required by the Personal Trading Policy in our region, we obtain

pre-clearance to trade any securities.

We may also be subject to additional trading restrictions because of our involvement with a

particular company or CIBC line of business. This includes situations in which (i) we have or

support an account relationship with a company; (ii) we have management responsibilities of a

company; or (iii) we are otherwise involved with a company on behalf of CIBC.

Trading CIBC Shares

Trading in CIBC shares is subject to a number of restrictions in addition to those that apply to

trading shares of other companies. These additional restrictions apply to all CIBC employees when

trading in CIBC shares.

Managing Inside Information

Employees are prohibited from disclosing Inside Information, except as required in the normal

course of business. We will comply with information barriers that have been established to control

the flow of Inside Information. We must also inform anyone who receives Inside Information from us

that they are subject to the same restrictions regarding its disclosure.

Trading Dos and Donts:

Dont: trade on Inside Information or advise others to do so

Do: obtain pre-clearance to trade when required

Do: remember the special rules for trading CIBC shares

Q What is Inside Information?

Inside Information is: material, non-public information about a public company (including

CIBC) that, if disclosed, would likely affect the market price of the companys securities or that

a reasonable investor would likely consider important in making an investment decision to buy,

hold, or sell securities.

Q What are some examples of securities?

Generally, securities are issued by a company to investors and represent either a portion of

the ownership of the company or an obligation on the part of the company to repay some form of

indebtedness to the investor. There are many different types of securities, but the most common

examples are shares and bonds. Other examples include derivatives, bank notes and debentures.

Q I have Inside Information about a company. Can I tell my spouse to buy or sell shares of

this company?

No. You cannot buy or sell any shares of this company or advise anyone else to do so until the

information has been disclosed to the public.

Q What additional restrictions apply when trading in CIBC shares?

CIBC employees, including employees of CIBCs wholly-owned subsidiaries, are prohibited from:

trading in put options, call options, or forward derivative contracts on CIBC shares;

trading any other over-the-counter derivative products designed to hedge exposure to CIBC shares; or

short selling CIBC shares.

Certain employees are also subject to restrictions regarding the timing of trading CIBC securities.

These employees are not permitted to buy or sell CIBC securities during Blackout Periods or

outside Window Periods (as the case may be).

2.7 Competing Fairly

CIBC vigorously competes in the marketplace and does so ethically, fairly and legally. CIBC

can and does gather data about its competitors; however, we will not communicate, acquire or use

trade secrets or proprietary information of others unless we have the right to do so.

Anti-trust and competition laws prohibit CIBC from engaging in activities that lessen competition,

such as agreeing with other financial institutions or businesses on the terms of a transaction,

product or service to be offered to third parties. Such terms may include interest rates, prices,

charges or types of services. In addition, we will not agree with other financial institutions or

businesses to avoid competing for clients in particular product categories or geographic markets.

Certain tied selling regulatory requirements prohibit us from proposing or entering into

transactions with clients that are conditional on the client: (i) bringing additional business to

CIBC; (ii) purchasing additional products from CIBC; or (iii) agreeing not to purchase a

competitors products. Where permitted, cross selling and relationship pricing are not considered

tied selling, and are therefore not prohibited under the Code.

Competition guidelines are very complex and certain exceptions may apply. Any concerns about

proposed dealings with competitors should be discussed with the Legal Department.

2.8 Respecting Copyright

Printed, broadcast, recorded or online materials and software are often protected by copyright

law. We must exercise caution and may need to seek prior approval from the copyright holder before

making copies of, distributing or otherwise using such material. If there is any doubt, the Legal

Department should be consulted.

Treating Everyone with Respect

3.1 Protection Against Harassment and Discrimination

As part of CIBCs mission to create an environment where all employees can excel, CIBC is

committed to diversity and employment equity in the workplace. Each of us has the right to be

treated fairly, equitably, with decency and respect and each of us must treat others, including

employees, clients, suppliers and the public, in the same way. Harassment or discrimination of any

sort is strictly prohibited.

3.2 Safety and Security in the Workplace

Each of us has the right to work in an environment that is safe and free of violence. We must

familiarize ourselves with and follow local policies, guidelines and procedures relating to health

and safety in the workplace.

Violence (physical or otherwise, including threats, sabotage, bullying and taunting) is strictly

prohibited at CIBC.

3.3 Avoiding Alcohol and Drugs

While on CIBC premises, participating in a CIBC-sponsored activity, or otherwise working on

behalf of CIBC, we are not allowed to be:

impaired by alcohol or drugs; or

in possession of illegal drugs.

The consumption of alcohol is strictly prohibited on CIBCs premises except at designated functions

that (i) have received either a onetime or ongoing approval from a Vice President (or Managing

Director in Wholesale Banking or CIBC Wood Gundy) or a more senior executive and that (ii) are

under the direct supervision of a manager who is responsible for the function. Managers responsible

for a function at which alcohol will be served must ensure that reasonable procedures and

safeguards are in place so that any serving and consumption of alcohol is managed in a safe and

responsible manner.

If we consume alcohol at a CIBC function, we will do so responsibly and we will not use any means

of transportation that jeopardizes our safety or the safety of others.

Each of us has the right to be treated fairly, and with decency and respect, and we

must treat others... in the same way.

3.4 Political or Religious Activity

While CIBC respects our right to our individual political and religious beliefs and practices,

we must not carry on these practices in a way that reflects upon CIBC as an organization, or that

affects other CIBC employees.

All requests for political contributions by or on behalf of CIBC must be directed to Communications

and Public Affairs for approval. For any political contributions, whether CIBCs or our own

individual contributions, we must be sensitive to any situation where the contribution might appear

to be for the purpose of obtaining a benefit for CIBC.

We may not carry on political activities or engage in religious advocacy on CIBC premises or

facilities. This includes seeking contributions, campaigning, and promoting political or religious

causes, beliefs or practices. This in no way limits our right to observe our individual political

or religious beliefs and practices in a private manner that does not have an impact upon other CIBC

employees.

Avoiding Conflicts of Interest

Avoiding conflicts of interest goes a long way towards helping ensure that we avoid behaviour

that is unethical or that otherwise contravenes the Code. We must avoid any situation where our

personal interest may conflict, or appears to conflict, with the interests of CIBC or of a supplier

or client of CIBC. Examples of such situations include:

where we, our family or close personal friend are in, or may be seen to be in, a

position to benefit personally from information we receive or authority we have as a

result of our role at CIBC;

where we are in a direct reporting relationship with someone with whom we share a close

personal relationship or would be seen to benefit personally from the reporting relationship;

where friendship or other close personal relationship may appear to adversely affect our

judgment or objectivity.

We must discuss any real, potential or perceived conflict of interest situation with our manager as

soon as possible so that steps can be taken to resolve the situation.

Sections 4.1 to 4.6 of the Code describe some situations of actual or apparent conflict of

interest, but the list is not exhaustive. If you have questions about a particular situation, speak

to your manager or to the Compliance Department.

4.1 Offering and Accepting Gifts or Other Benefits

In this section, gift or other benefit includes entertainment.

Giving a gift or other benefit to, or receiving a gift or other benefit from, certain entities or

individuals may give rise to a conflict of interest, especially where the gift or other benefit is

of more than nominal value.

Even where a conflict does not exist, the gift or benefit may be viewed as an attempt to influence

a business decision. For this reason, CIBCs Gifts and Entertainment Policy includes a number of

restrictions that apply when giving or receiving gifts or other benefits.

Discuss any real, potential or perceived conflict of interest situation with your manager as soon as possible.

4.2 Personal Borrowing and Lending

We will not borrow from or lend personal funds or other

personal property to any client or supplier who has an ongoing or

potential relationship with CIBC, or use this relationship so that

others, who are either related to us or are close personal friends

of ours, can do so. This restriction does not apply to:

transactions with family members; or

transactions with clients who are financial intermediaries

(such as department stores or other financial institutions) if

the transaction is conducted on market terms and conditions.

We will avoid borrowing from or lending personal funds to

another employee, particularly someone we supervise.

When should borrowing from or lending to an employee be avoided?

Personally borrowing from or lending to another employee should be avoided in cases that

would likely result in a real or apparent conflict of interest. A conflict of interest might

exist if:

the amount borrowed is more than nominal;

borrowing from or lending to this employee has occurred on numerous occasions;

either employee might be under any undue pressure as a result of the borrowing/lending; or

there is a reporting relationship between the employees involved.

4.3 Treatment and Selection of Suppliers

Suppliers should be treated fairly and should be chosen based strictly on value, quality,

service and price. CIBC strives to deal with suppliers that have high standards of business conduct

that are in keeping with CIBCs standards.

4.4 Beneficiaries, Fiduciaries and Powers of Attorney

If you discover that a client (other than a family member) is considering making or has

already made you a beneficiary, executor or other personal representative in a will or a trust, you

must advise your manager and the Compliance Department. Where the client has not yet made the

designation, you should discourage the client from doing so.

Accepting signing authority or a grant of power of attorney from a client regarding a clients

account (other than that of a family member) typically creates a conflict of interest and should be

avoided. If you discover that such an appointment or assignment of authority has been made, you

must immediately inform your manager and ask the client to revoke the authority or appointment.

Compliance Department approval is required for any exceptions.

CIBC reserves the right to require an employee to renounce any bequest or appointment or to remove

himself or herself from dealing with a clients estate where there exists an actual or apparent

conflict of interest.

This section does not restrict CIBCs ability to receive discretionary trading authority from our

clients, where that is allowed under applicable laws. Refer also to section 4.5 below

4.5 Engaging in Outside Activities and

Investments

Those of us who are full-time employees must devote our entire business day to our work. In

addition, it is important that all employees avoid any outside activity, employment, position,

association, or investment that might interfere with, or might appear to interfere with, the

independent exercise of our judgment regarding the best interests of CIBC and its clients. For

these reasons, we may be required to obtain written approval for, to limit or to resign outside

positions or interests.

Each individual has a personal responsibility to uphold the principles of the

Code.

When is Approval Required?

We must discuss our obligations under the Code with our manager and

complete the Outside Activities Approval Request Form before:

accepting additional employment outside of CIBC;

carrying on business activities outside of CIBC;

holding a controlling interest in a public or private business;

taking a financial interest in a business more directly

than a market transaction in the securities of a publicly

listed company;

serving as a personal representative (such as trustee,

executor, guardian, or through the grant of a power of

attorney) for a client (other than a family member) with

whom we or our business unit have a relationship; or

commencing a campaign for election or appointment to public

office, whether paid or unpaid.

Boards of Directors

If CIBC asks you to act as a director of a CIBC subsidiary, request

approval by contacting the Compliance Department or other designate

for your region. For any other position as a director of a company,

organization or association, or as a member of a board advisory

committee, speak to your manager and complete the Outside Activities

Approval Request Form.

Annual Certification

Every year, as part of CIBCs Mandatory Training and Testing

Program, each of us must provide a certification regarding any

outside activity, employment, position, association, or

investment.

Does acting as a director of a not-for-profit organization or association require pre-approval?

Yes. Acting as a director or sitting on a board advisory committee of such an organization or

association requires approval under the Code. Discuss the position with your manager and complete

the applicable Outside Activities Approval Request Form.

When In Doubt, Fill It Out

The key factor in determining whether an activity requires approval is whether it creates a

real or apparent conflict of interest. Factors to consider include:

Your role at CIBC: Are you in a client-facing role? Do you have access to client information?

Are you a securities registrant (i.e., registered with IIROC, the MFDA, FINRA, the FSA,

or other regulatory agencies)?

Will the activity require your involvement with a competitor, client or supplier of CIBC?

How much of your time will be devoted to this activity?

If in doubt, talk to your manager and complete the Outside Activities Approval Request Form or

contact the Compliance Department.

4.6 Processing Personal Transactions

Processing transactions for ourselves or for those close to us can create a conflict of

interest. We are allowed to process these transactions only where a written policy or guideline

permits it. Otherwise, we must not process, or require another employee to process, a transaction

for ourselves, for a member of our Immediate Family (see definition below), for anyone for whom we

are serving as a personal representative (such as trustee, executor, guardian, or through the grant

of a power of attorney), or for anyone with whom we share a significant personal or financial

interest.

Immediate Family includes an individuals: spouse or common law partner, parents,

sisters/brothers, children, parents-in-law, sisters/ brothers-in-law, step-children, grandparents,

step-sisters/brothers, grandchildren, legal dependents, legal guardian, or any corporation or other

legal entity that is controlled by that individual and/or members of the individuals Immediate

Family.

Protecting Our Brand, Clients, Investors, Employees and the Environment

5.1 Representing CIBC

In the eyes of our clients and the community, each of us represents CIBC. While we have the

right to publicly express our personal views, we will not, under any circumstance, participate in

activities that may compromise CIBCs image or reputation. This includes activities that would

disparage, defame, embarrass or harass CIBC, its employees, its clients or its suppliers. This

applies to expressing views by any medium, including in print, or via the Internet (including by

blogs, online social network, e-mail or on webpages).

Using CIBCs Brand Name and Trademarks

We will use CIBCs brand name and trademarks outside CIBC only as part of the regular duties of

our job or at an external function where CIBCs participation has been previously approved.

Lobbying Activity

Employees who communicate on behalf of CIBC with government officials must ensure that they comply

with applicable lobbying activity approval and reporting requirements.

Public Speaking

If we will be speaking at a public forum in a professional capacity or as a representative of CIBC

(e.g., speaking at a school or professional conference), we will obtain the prior approval of our

manager. Further, if the situation involves speaking to the media, or otherwise being seen as a

spokesperson for CIBC, we will obtain the prior approval of Communications and Public Affairs.

In the eyes of our clients and the community, each of us represents CIBC.

5.2 Community Activity

As part of CIBCs mission to make a real difference in our communities, CIBC supports employee

involvement in community activities. We must be aware of the fact that in participating in those

activities, we are, or may be seen to be, representatives of CIBC.

When soliciting charitable donations, whether on behalf of CIBC or another organization, we will

emphasize the voluntary nature of the donation. We will not place employees (particularly those who

report to us, directly or indirectly), clients or suppliers in a position where they may feel

obligated to contribute for fear of being treated unfairly if they refuse. None of us should feel

pressured to contribute to fundraising campaigns, either by co-workers or by CIBC.

5.3 Full and Fair Disclosure

All of our communications must be truthful, accurate and complete, and must not mislead

others.

This standard applies when we are preparing or providing information for inclusion in any report,

system, document or other communication, whether written, oral or electronic, and whether directed

to an internal or external recipient.

If we are unsure as to the accuracy or completeness of information we have received, we should

consult with our manager.

We will never make any false or misleading entries, misrepresent a clients financial position, or

forge, tamper with, or otherwise misuse anyones identity or signature. In addition, we will not

by-pass procedures designed to ensure the integrity of CIBCs records or to ensure full and fair

disclosure.

All of our communications must be truthful, accurate and complete, and must not mislead

others.

5.4 Guarding Against Misleading Marketing

and Communication Materials

To ensure that clients, investors and the public are protected

against misleading statements and that clients receive sufficient

information to make informed decisions, all marketing and

communication materials must be approved in advance by the Legal

Department and/ or the relevant Customer Marketing Department.

5.5 Environmental Responsibility

CIBC is committed to acting responsibly in all of its activities

by: (i) protecting and conserving the environment; (ii) safeguarding

the interests of all CIBC stakeholders against unacceptable levels of

environmental risk; and (iii) supporting the principles of

sustainable development.

Each of us is responsible for taking reasonable care to ensure that

CIBCs business activities are conducted in an environmentally

prudent way.

Is it acceptable to skip a step required by a CIBC policy or procedure to save time

for a client?

No. Although policies and procedures may sometimes seem cumbersome, remember that they have

been carefully designed to support complying with the law and protecting CIBCs reputation.

Skipping a step could put you, CIBC or our clients at risk. If you have a question or comment

concerning a policy or procedure, discuss this with your manager or raise it with the owner of the

policy or procedure.

Our Role in Using and Safeguarding Information and Assets

6.1 Protecting Confidentiality and Privacy

To honour CIBCs value of trust, we must take all reasonable

steps to preserve the confidentiality of general, personal and

corporate information of CIBC and of its stakeholders (including

existing, former or potential: clients, employees, directors,

shareholders, and suppliers). We will access and use this

information only for the purposes intended, as directed by our

manager or business unit procedures, and share it only with those

who have a need to know, consistent with those purposes.

If we have concerns regarding the protection of client or

employee personal information, or become aware of a breach of

confidentiality or privacy obligations, we will communicate those

immediately to the Privacy Office.

We will read, use or disclose client or employee information only

when we have a business purpose for doing so. We understand that

CIBC may monitor account inquiries for the purpose of detecting

unauthorized access.

My good friend is going through a divorce and asked me to monitor her

husbands CIBC accounts and let her know if he makes any large withdrawals. I made inquiries on

the accounts but didnt notice any large withdrawals and decided not to advise my friend of the

activity. Is this a privacy breach?

Yes. Accessing client information without the clients consent and without a business reason

to do so is a privacy breach.

Is it acceptable to send CIBC confidential information to my personal e-mail account

so that I can use this information to work from home?

No. Never send or forward CIBC confidential information to or from your own personal e-mail

account. To e-mail confidential information externally, follow the guidance on e-mail use provided

in CIBCs Acceptable Use of Computing Systems and Information Policy.

The Code says that CIBC may monitor account inquiries for the purpose of

detecting unauthorized access. If I access my own personal account, might that still be

unauthorized access?

Yes, particularly if the information you have accessed is information that is not normally

available to a client.

6.2 Maintaining Information Security

CIBC controls and monitors the use of its network (including

all forms of electronic messages), computing facilities and

voicemail system, and can restrict use of or withdraw access

privileges to these systems and facilities without prior notice.

In addition, CIBC may conduct investigations of potential

violations of any CIBC policy based on this information.

We must all exercise good judgment when using these systems and

facilities, whether personally or for CIBC purposes.

We will not use CIBCs systems or facilities to access, download,

or distribute information that may be considered offensive,

illegal, unethical or discriminatory, or that could harm CIBCs

reputation.

Personal use of the Internet and e-mail must not interfere with

our normal duties or the effective operation of CIBCs network

and computing facilities. We may use CIBCs computer resources

only if the use is in accordance with CIBC policies that govern

their use.

We may use CIBC computer resources when working from non-CIBC

locations if we use approved technology and channels, provided

that our manager has approved of such use and all confidential

information is protected from theft or unauthorized access.

We are accountable for all activity carried out using our

individual IDs or passwords and we will not share our IDs or

passwords with anyone for any reason.

Why is it important to follow my business units clean desk

procedures?

Following clean desk procedures is essential to help protect information of CIBC, its clients,

employees and other stakeholders from loss or exposure to unauthorized parties. Information that

is lost or disclosed to unauthorized parties can disrupt business processes and damage CIBCs

reputation.

My friend gave me software that would be very helpful to me in my work. Can I install it

on my CIBC computer?

No. Do not attempt to install software, software updates, or software components from any source,

including the Internet, yourself. Ensure that all software installed on your computer is installed

by CIBC staff authorized to do so.

6.3 Safeguarding CIBCs Assets

CIBCs facilities, equipment, information, and other assets are CIBC Property. Except as

permitted under section 6.2 above, CIBC Property must be used only for CIBC purposes.

We must adhere to control measures that have been implemented to protect CIBC Property. These

measures may include use of security equipment such as safes or vaults, physical or logical access

control, or other security-related processes.

As soon as we are no longer employed by CIBC, we will no longer use, access or disseminate CIBC

Property and we must promptly return all such property to CIBC.

6.4 Following Business Expense Policies

If we incur expenses or approve expenses on behalf of CIBC, including expenses incurred

through the use of a corporate credit card, we will comply with the requirements outlined in the

CIBC Employee Expense Reimbursement Policy and CIBC Business Unit Purchasing Policy. This includes

ensuring that all expenses are for a valid business purpose and are reasonable in relation to the

business requirements and the goods and/or services being provided.

6.5 Maintaining Records

If CIBCs records are incomplete or inaccurate, the trust of our stakeholders and the

integrity of our reputation may be compromised.

We must ensure that all CIBC client, employee, general and corporate records comply with CIBCs

policy on the creation, retention and destruction of records. Each of us is responsible for the

integrity of books and records under our control.

Cooperating with Internal and Regulatory Investigations

We will cooperate unconditionally with any CIBC department that audits, tests or

investigates issues within CIBC.

We will also cooperate with lawful investigations and inquiries from third parties, including

regulators, enforcement agencies, or parties involved in litigation. If we receive any kind of

demand or request for information from a third party, we must contact the appropriate CIBC

department as follows:

for search warrants in Canada, contact Corporate Security immediately, and in all

other jurisdictions, contact the Legal Department;

for regulatory requests or notices of investigation, contact the Legal Department or

Compliance Department;

for all other demands or requests, follow existing business procedures or contact the

Legal Department or Compliance Department.

In all cases, we will contact the appropriate department before we tell the requesting party

whether the information exists at all, discuss any information with the requesting party, provide

the information requested, or tell any affected employee, client or supplier about the request.

If we receive any kind of demand or request for information from a third party, including a

government agency or regulator, we must contact the appropriate CIBC department

Contravention of The Code

Contravention of any provision of the Code may result in

disciplinary action up to and including termination of employment

without notice, in addition to possible civil, criminal or

regulatory action. Such conduct may also affect individual

performance assessment and compensation.

Your Obligation to Report Code Violations

As part of being accountable to each other and to CIBC, each of us

has an obligation to report all apparent contraventions of the

Code by speaking to our manager or to the appropriate contact

listed in section 9 of the Code, by calling the confidential

Ethics Hotline, or as otherwise provided in the Code or in an

applicable policy.

Any report of concern about conduct that may contravene the Code

will be treated confidentially to the extent possible and in a

manner consistent with CIBCs responsibility to address the issue

raised.

Protection from Retaliation

No one may retaliate or take adverse employment action against an

employee who, in good faith, reports an actual or apparent

contravention of the Code, or who provides information or

assistance for an investigation.

I am not comfortable discussing a potential Code violation with my manager. What other

options are there?

If you do not feel comfortable reporting a potential Code violation to your manager, you should

speak to your managers manager about the situation. If this is also a concern, you may report the

issue to the appropriate individual or group listed in section 9 of the Code. If you wish to remain

anonymous or if you feel that someone has not responded appropriately to your report, you can call

the confidential Ethics Hotline. All reports of potential Code violations are considered

confidential, are taken seriously and are investigated fully.

Seeking Advice

Omitted