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| Overall Assessment |
Comment |
Score |
| Comprehensive |
Canadian Imperial Bank of Commerce provides a high level of detail about its climate-related public-policy engagement. It names multiple identifiable policies it has worked on, including OSFI’s “Guideline B-15: Climate Risk Management,” consultations on the Government of Canada’s “Green Financing Framework,” the “Canada Growth Fund,” the “CCUS Investment Tax Credit,” and other clean-economy investment tax credits announced in Budget 2023. The bank also describes how it seeks to influence these measures. It cites indirect lobbying “through the Canadian Bankers Association (CBA) to provide comments regarding OSFI’s draft guideline,” reports that it “participated in a consultation on net-zero industrial policy hosted by Canada’s Net-Zero Advisory Body,” and details “structured consultations with the Government of Canada” as well as technical briefings with Finance Canada, showing both the mechanisms used (consultations, technical briefings, written comments, trade-association submissions) and the specific government bodies targeted (OSFI, Department of Finance Canada, Net-Zero Advisory Body). CIBC is equally explicit about the outcomes it is seeking: it supports the creation of “a prudential framework that is more climate-sensitive and includes mandatory climate-related financial disclosures aligned with TCFD,” advocates for “the inclusion of nuclear energy” in the Green Financing Framework to enlarge the supply of labelled bonds, backs the Canada Growth Fund’s use of carbon contracts for difference to give price certainty, and calls for investment tax credits that will “attract investment and increase competitiveness in the clean-energy transition.” By disclosing the specific policies, engagement channels, targets and desired regulatory changes, the bank demonstrates comprehensive transparency around its climate-policy lobbying activities.
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4
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| Overall Assessment |
Comment |
Score |
| Moderate |
Canadian Imperial Bank of Commerce discloses a governance structure that links climate-related stakeholder engagement to high-level oversight, indicating moderate control over how policy interactions are aligned with its climate ambitions. The company states that it has “an established governance structure that includes Board oversight, the role of management in climate-related decisions, and internal accountability for execution across the entire enterprise” and that “the Board delegated to the Corporate Governance Committee oversight of our overall ESG strategy and related stakeholder engagement, alignment with our purpose and disclosure on CIBC’s ESG practices and performance against targets.” Named individuals and bodies are clearly accountable, with “Accountability for our climate strategy … held with our Executive Vice-President and Chief Legal Officer (EVP and CLO), who … chairs our Senior Executive ESG Council,” while the Council’s role is to “align CIBC on delivering against its ESG strategy, including our climate strategy, evaluating and monitoring progress.” These disclosures demonstrate a policy and process for overseeing external engagement and identify specific senior executives and committees responsible for monitoring alignment, which indicates a degree of governance over lobbying-type activities. However, the evidence does not detail any concrete mechanisms for assessing or correcting the climate-policy positions of trade associations, nor does it reference a dedicated lobbying policy, systematic lobbying reviews, or a public climate-lobbying alignment report; thus “the company does not disclose how it evaluates the climate positions of its industry associations or whether it amends, escalates, or withdraws membership when misalignment occurs,” and no examples are provided of direct lobbying decisions being assessed against climate targets. Consequently, while oversight responsibilities are explicit, the absence of procedures or audits covering both direct and indirect lobbying limits the strength of the governance framework.
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2
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