We have developed a number of measures to help us achieve the highest standards of ethical behaviour.
CIBC’s Code of Conduct sets out the principles and standards for ethical and professional behaviour in everything we do.
The Code applies to all employees of CIBC and our wholly-owned subsidiaries, including both regular and temporary employees working either full or part time. The Code also applies to consultants, independent contractors and temporary agency staff providing
services to CIBC (collectively “contingent workers”). Our Board of Directors is bound by a similar Code and our employees, contingent workers and Board members are required to certify their code compliance each year.
Key areas and obligations covered by the Code include:
Potential consequences for violations of the Code include termination of an individual’s employment or contractual engagement without notice, as well as civil, criminal or regulatory proceedings.
Anti-bribery and anti-corruption
CIBC’s Code of Conduct states that, “we will not engage, directly or indirectly, in bribery, kick-backs, payoffs or other fraudulent or corrupt business practices.” If an employee or contingent worker is approached by an employee, contingent worker, vendor, client, government representative or other third party with an opportunity to engage in such activity, he/she is required to report the incident to his/her manager, to Corporate Security or to the Ethics Hotline.
In addition, CIBC has a policy that establishes minimum standards of conduct related to gifts or entertainment given to or received from government officials as well as private persons. These standards include a prohibition on gifts or entertainment given corruptly (including facilitation payments). Employees and contingent workers learn about this policy as part of CIBC’s annual mandatory Code of Conduct training and testing program. Employees in certain geographic regions also receive customized periodic communication of the policy’s requirements.
Anti-money laundering and anti-terrorism financing
CIBC has an enterprise-wide program to protect the safety, soundness and reputation of CIBC by meeting or exceeding the regulatory requirements relating to anti-money laundering and anti-terrorist financing in each jurisdiction in which we operate. The program helps us detect, deter, and report suspected money laundering and terrorist financing activities.
Our focus is on minimizing the risk that CIBC or our employees will become involved in money laundering or terrorist financing activities, whether inadvertently or otherwise. We stay informed about evolving trends and techniques to counter such risk, consult on an ongoing basis with external experts, and provide regular training to help our employees stay abreast of ongoing changes.
