Canadian Imperial Bank of Commerce

Lobbying Governance

AI Extracted Evidence Snippet Source

###### 2.0 Governance\n\n###### Through Board oversight and executive management accountability for our climate strategy and climate risk management, we are integrating climate considerations into our business.\n\nCIBC has an established climate governance structure within an overall ESG governance framework that drives accountability and supports alignment of climate-related activities across the enterprise. This governance framework allocates responsibility for our ESG strategy,[(1)] including climate-related activities, among the Board of Directors (the Board), executive management, strategic business units (SBUs), and functional groups. It also allows for monitoring, evaluating, and responding to risks and opportunities posed by climate change. Our approach to climate governance supports the ongoing advancement of our climate-related priorities across the bank by outlining where responsibility lies and the distinct roles of Board committees and management-level business functions in overseeing and making decisions on climate-related risks and opportunities to support our climate strategy.\n\n###### 2.1 CIBC's Climate Governance Framework\n\n**Oversight**\n\n|Oversight|Col2|Col3|Col4|\n|---|---|---|---|\n|CIBC Board of Directors|||||\n|The Board of Directors has oversight of CIBC's ESG strategy, including our climate strategy, and how CIBC is measuring, evaluating, and monitoring progress against strategic climate goals.|||||\n|Overall ESG Strategy and Engagement|Specific Execution of ESG Elements Based on Mandate|||\n|Corporate Governance Committee|Risk Management Committee|Management Resources and Compensation Committee|Audit Committee|\n\n|Executive Management|Col2|\n|---|---|\n|Senior Management(2)||\n|EVP and Chief Legal Officer|SEVP and Chief Risk Officer|\n|Executive lead for ESG across enterprise, including accountability for climate strategy.|Executive accountable for climate risk management.|\n|Disclosure Committee||\n|Executive-level Committee that reviews ESG disclosures following internal reviews, as part of final steps in our ESG Disclosure Review Framework.||\n|ESG Strategy and Governance|Risk Management|\n|Senior Executive ESG Council|Global Risk Committee|\n|Chaired by the Executive Vice-President and Chief Legal Officer, the Council's purpose is to align CIBC on delivering against its ESG strategy, including our climate strategy, evaluating and monitoring progress, and tracking against set commitments.|Chaired by the Senior Executive Vice-President and Chief Risk Officer, provides a forum for discussion and oversight of risk appetite, profile, stress testing, and mitigation strategies, including consideration of relevant environmental or climate-related risks.|\n\n###### 2.1 CIBC's Climate Governance Framework\n\n**Execution**\n\n|Execution|Col2|Col3|Col4|\n|---|---|---|---|\n|Governance and Execution Support|||||\n|Committees and Working Groups|||||\n|Executive-Level|Business-Level||Regional|\n|Reputation and Legal Risks Committee High Carbon Risk Review Committee 2030 Financed Emissions Target Steering Committee (target-specific)|Capital Markets ESG Committee Sustainability Issuance Council||Regional Climate Risk Committee (Europe & APAC) CIBC Caribbean ESG Council|\n|||||\n|Select Key Functional Group and Strategic Business Unit Teams supporting execution against our climate strategy|||||\n|Enterprise ESG Climate Strategy, Disclosure, and Governance Global Operational and Enterprise Risk Management Environmental Risk Management Finance ESG Reporting, Treasury, Investor Relations||Capital Markets Energy, Infrastructure and Transition (EIT), Sustainable Finance, Sustainability Advisory Commercial Banking and Wealth Management Real Estate Finance Personal and Business Banking Personal Banking Products and Payments||\n\n###### 2.2 Board oversight\n\nThe Board is responsible for the oversight of CIBC's strategic plans and priorities. In fulfilling this responsibility, the Board considers CIBC's purpose and ESG strategy in our business operations and decision making. Oversight of our ESG strategy, including our climate strategy (discussed in Section 3), is led by the Corporate Governance Committee (CGC) while oversight of principal business risks, including climate-related risks, is led by the Risk Management Committee (RMC). All Board committees provide oversight on relevant components of our ESG strategy, including climate strategy and governance, based on their respective committee mandates.\n\n**Oversight body**\n\nBoard of Directors\n\nCorporate Governance Committee\n\n**Frequency of climate-**\n**related updates to body** **Role in climate oversight** **Examples of climate-related activities in 2024**\n\nQuarterly \n\nOversees ESG strategy, including climate strategy, related metrics and goals, ESG governance, as well as climate-related disclosure and stakeholder engagement practices.\n\n- Supports coordination and alignment across the entire Board by reviewing a quarterly summary of other committees' ESG-related updates, including those related to climate.\n\n- Dedicated ESG agenda time during quarterly meetings and received quarterly updates, including climate-related information. These updates include progress toward established 2030 financed emissions reduction targets, stakeholder expectations, industry and regulatory developments, insights from CIBC's participation in climate-related industry forums, and business activities from regions across CIBC's global footprint.\n\n- Reviewed CIBC's 2023 Climate Report and 2023 Sustainability Report.\n\n**Oversight body**\n\n**Frequency of climate-**\n**related updates to body** **Role in climate oversight** **Examples of climate-related activities in 2024**\n\nAudit Committee Quarterly - Oversees processes and controls around ESG disclosure in the Annual Report, Sustainability Report, and other material ESG disclosure documents.\n\n - Reviews the integrity of material ESG disclosures and monitors CIBC's compliance with legal and regulatory requirements related to ESG disclosure.\n\n- Reviewed CIBC's ESG disclosure in the Sustainability Report, Climate Report and Annual Report, including Management's Discussion and Analysis (MD&A).\n\n- Received updates on regulatory developments related to ESG reporting and associated trends.\n\n- Reviewed processes and controls for data collection and reporting for ESG disclosure in the Sustainability Report, Climate Report and Annual Report, including the MD&A.\n\nTo support these oversight responsibilities, the Board and its committees remain informed about climate trends, risks, and opportunities for CIBC, receiving regular updates on CIBC's key climate actions, including through director development initiatives outlined below. CIBC's Board members, including the Chair, also engage directly with investors and other key stakeholders to discuss our climate plans and receive direct feedback on progress.\n\nFurther details on how climate change is considered in Board oversight, along with specific committee activities, can be found in our Statement of Corporate Governance Practices in CIBC's [Management Proxy Circular.](https://www.cibc.com/content/dam/cibc-public-assets/about-cibc/investor-relations/pdfs/annual_meetings/management-proxy-circular-2025-en.pdf)\n\n###### Senior Executive ESG Council\n\nOur Senior Executive ESG Council (Council) continues to champion CIBC's ESG strategy, including our focus on accelerating climate action. One of its main objectives is to ensure input from all SBUs and functional groups is integrated into bank-wide ESG initiatives including those related to climate. In 2024, the Council provided input into topics such as the 2030 financed emissions reduction target-setting approach for CIBC's automotive manufacturing portfolio, CIBC's sustainable issuance framework and methodology, and updated ESG Index metrics to measure performance. The Council was also kept up-to-date on emerging climate-related regulations, industry developments, and investor perspectives.\n\nOur Enterprise ESG team works with SBUs and functional groups to provide input into Council agendas and supports the preparation of reporting materials that focus on both internal activities and external trends and insights. This reporting is intended to enhance the coordination of ESG activities, including climate-related activities, across the bank and deliver against our ESG and climate strategies, monitor progress, and track performance against our set commitments. These efforts are further supported by a broader group of team members with deep ESG or climate-specific expertise who help drive initiatives across our teams. Additionally, functional-level and topic-specific committees and working groups, listed below, play a critical role in these efforts.\n\n**Committees and**\n**working groups**\n\nSenior Executive ESG Council\n\nDisclosure Committee\n\nGlobal Risk Committee\n\nReputation and Legal Risks Committee\n\n2030 Financed Emissions Target Steering Committee\n\nHigh Carbon Risk Review Committee\n\n**Climate-related**\n**agenda frequency** **Membership** **Chair** **Role in Climate strategy, Governance, and/or Risk management**\n\n**Executive level**\n\nAnnually Senior Executive, Executive, and Senior Vice-Presidents from across the bank\n\nQuarterly Executive and Senior Vice-Presidents from across the bank\n\nAs needed Executive and Senior Vice-Presidents from non-SBUs\n\nAs needed Senior leaders from relevant business units, Risk Management, and Enterprise ESG\n\nAs needed Senior leaders from relevant business units and Risk Management\n\n- Promotes consistent disclosure practices aimed at accurate, complete, timely, and broadly disseminated disclosure of material information about CIBC to the market, including the Climate Report, to ensure any material information is appropriately included and is consistent with other relevant CIBC public disclosures.\n\n- Provides a forum for discussion and oversight of risk appetite, risk profile, and risk mitigation strategies, including consideration of relevant environmental or climate-related risks.\n\n- Provides a forum to determine whether any factors, including environmental and climate-related considerations, associated with a particular matter or transaction could create reputation or legal risks for CIBC.\n\nNot applicable • Oversees CIBC's methodology and target-setting approach for sector-specific 2030 financed emissions reduction targets. Feedback is solicited to support critical decision-making, which includes reviewing feasibility of setting targets, in addition to approving the approach used for targets that are set, ensuring accuracy and relevance to CIBC's business. This committee is convened as needed and composition changes based on the specific target and subject matter.\n\n- In transactions where Carbon Risk Scoring is required, clients are assessed against CIBC's requirements and standards to evaluate how clients are responding to carbon-related transition risks.\n\n- Reviews clients who have scored poorly to determine how CIBC can best support their transition activities and identifies high-emitting clients to discuss potential approaches for managing risk\n\nSVP and Chief Accountant\n\nSEVP and CRO\n\nSEVP and CRO\n\nAVP of Environmental Risk\n\n###### Enterprise-wide teams supporting climate action\n\nIn addition to supporting the effective oversight and management of our climate strategy, CIBC's climate governance structure supports its execution across the business. Our Enterprise ESG team — led by the Senior Vice-President of Corporate Governance and ESG (SVP of Corporate Governance and ESG) — facilitates engagement and action across all SBUs and functional groups. The Enterprise ESG team works in partnership with experts across the bank, including Environmental Risk Management and the Sustainable Finance and Sustainability Advisory teams in Capital Markets, to support the integration of climate-related risks and opportunities into our enterprise ESG strategy and bank-wide operations. Additionally, our Global Environmental and Social Framework provides an overview of how CIBC sets and operationalizes its ESG strategy and related policies, manages environmental and social risks, and outlines the established ESG governance framework.\n\nGlobal Operational and Enterprise Risk Management, which includes a dedicated Environmental Risk Management team that reports to the EVP, Global Operational and Enterprise Risk Management, provides independent oversight of the identification, measurement, monitoring, and management of climate-related risks. The team ensures climate considerations are incorporated into risk frameworks, policies, and risk appetite. Global Operational and Enterprise Risk Management is responsible for:\n\n- Measuring our 2030 financed emissions reduction targets[(1)] aligned with internally developed methodology and absolute financed emissions aligned with the Partnership for Carbon Accounting Financials (PCAF) methodologies;\n\n- Identifying and assessing CIBC's climate-related physical and transition risks over the short, medium, and long-term through the use of heatmaps and scenario analysis;\n\n- Embedding climate risks into overall enterprise risk management, including via carbon scoring methodology and measurement of carbon-related asset exposure; and\n\n- Monitoring and ensuring compliance with climate risk-related regulatory requirements.\n\n###### Compensation linked to climate-related targets\n\nA key aspect of CIBC's ESG governance framework is fostering enterprise-wide accountability. The scorecards for the CEO and Senior Management include ESG-related performance metrics, which are also reflected in business area performance measures, as appropriate.\n\nIn addition, incentive compensation awards take into consideration ESG performance through CIBC's ESG Index. The compensation of executives and the majority of employees is linked to individual behaviours and outcomes through the Individual Performance Factor (IPF) and company-wide performance, based on the Business Performance Factor (BPF), which is approved by the Board. The ESG Index accounts for 10% of the overall BPF, ensuring that achieving our ESG targets is a component of annual incentive compensation. We continue to maintain alignment between the internal ESG Index and our public scorecard for transparent disclosure of the link between ESG performance and annual incentive compensation.\n\nThe ESG Index tracks and quantifies progress on our ESG priorities, including our climate-related goals, and includes measures across SBUs and functional groups. ESG Index metrics and annual goals are tied to our public commitments across each ESG strategic priority, including those with multi-year objectives. Climate-specific metrics are reflected in the 2024 ESG Index through the Accelerating Climate Action strategic priority, which represents 34% of the total weight allocated to ESG strategic priorities. This includes measures related to sustainable finance,[(2)] operational greenhouse gas (GHG) emissions reduction goals (absolute Scope 1 and 2), and our 2030 financed emissions reduction targets. Performance on the ESG Index metrics is tracked and reported quarterly to Senior Management and the Board. The ESG Index is reviewed annually with input from the Senior Executive ESG Council and CIBC's Senior Management and receives final approval from the MRCC.\n\nFor more information on Executive compensation and CIBC's ESG Index, refer to CIBC's [Management Proxy Circular.](https://www.cibc.com/content/dam/cibc-public-assets/about-cibc/investor-relations/pdfs/annual_meetings/management-proxy-circular-2025-en.pdf)

https://www.cibc.com/content/dam/about_cibc/corporate_responsibility/pdfs/climate-report-2024-en.pdf

## 5. Governance and reporting

While this Methodology applies enterprise-wide, CIBC reports only on sustainable financing by lines of business and functional groups that currently have the necessary internal governance and review procedures in place, and does not fully capture the value of sustainable financing enterprise-wide, globally.[57]

CIBC has a quarterly internal governance and review process for each eligible sustainable finance transaction. Transactions are identified by applicable lines of business and functional groups and each transaction undergoes a review and approval process in line with the eligibility criteria under this Methodology. In addition, all transactions will be screened for compliance with CIBC's Lending Guidelines, Environmental Risk Policy, and any other applicable environmental and social risk management policies.[58] After undergoing the necessary diligence process in accordance with CIBC's policies and standards, the line of business or functional group submits the transaction for a multi-step review and approval process by teams independent of the transaction teams. This is comprised of representatives from specialist teams at the SBU level, the functional groups, Finance, and Enterprise ESG.

As necessary, CIBC aims to monitor, review, and update its internal procedures related to the review, approval, and quantification of eligible sustainable finance transactions. In addition, as the regulatory environment, market practices and industry standards, guidelines, frameworks, principles and regulations evolve, this Methodology will be reviewed and updated, as required. This may result in CIBC revising its SF Goal or the eligibility criteria, measurement methodology, or progress towards the SF Goal. From 2022 onwards, CIBC's Senior Executive Environmental, Social, and Governance (ESG) Council approves all changes to the sustainable finance methodology.

CIBC will report, on an annual and cumulative basis, its progress towards the SF Goal in one or more ESG-related reports.

https://www.cibc.com/content/dam/about_cibc/corporate_responsibility/pdfs/sustainability-finance-methodology-en.pdf

- **Staying informed through strategic partnerships and** **stakeholder engagement: The development of sectoral,** national, and global frameworks is a critical step in creating consistency and accountability to drive collective ESG progress. We anticipate that new ESG-related standards and regulations will be announced and formalized in the coming year. As these are fnalized, we plan to stay informed through stakeholder engagement, and share our perspectives through participation in key partnerships, industry associations, and councils, such as the Sustainable Finance Action Council, the Taskforce on Nature-related Financial Disclosures, the Net-Zero Banking Alliance, and RMI's Center for ClimateAligned Finance. Our thoughtful contribution to the broader sustainability ecosystem enables us to amplify our impact by partnering with organizations that are aligned with our values and committed to achieving meaningful ESG progress. [...] - **Strengthening enterprise-wide alignment through our** **ESG governance framework: We recognize that there are** increasing expectations for businesses to report on accurate and consistent information. In 2022, we introduced additional processes and controls through our ESG Disclosure Review Framework to support high-quality, accurate, and timely disclosure on our ESG priorities and performance, in order to maintain credibility with stakeholders. We will continue to enhance our governance processes in the next year, further integrating ESG across our strategic business units, functional groups, and regions, to increase connectivity, foster accountability, and improve transparency. [...] Our Board of Directors is well-prepared to oversee our ESG strategy. We will leverage the previous learnings provided to our parent, regional, and subsidiary Boards, through our ESG Director Development program, with a new series examining the intersection between environmental and social issues, such as energy afordability and security. Drawing on external expertise, as required, our program will capture diverse viewpoints and refect current and emerging ESG themes."
"Accountability for our climate strategy is held with our Executive Vice-President and Chief Legal Ofcer (EVP and CLO), who reports into our President and CEO and chairs our Senior Executive ESG Council. Our EVP and CLO is the Executive owner of ESG strategy across the enterprise, which includes our climate strategy. Our strategy is led and facilitated by the Enterprise ESG team and our strategic business units and functional groups deliver on the outcomes. The Senior Executive Vice-President and Chief Risk Ofcer (SEVP and CRO), who leads our Environmental Risk Management function, is the executive accountable for initiatives that manage climate risk across the business. Our CRO is responsible for identifying, assessing and managing climate-related impacts on CIBC, and approves CIBC's frameworks and policies on the identifcation and control of risks, including climate-related physical and transition risks.

https://www.cibc.com/content/dam/cibc-public-assets/about-cibc/corporate-responsibility/documents/cibc-sustainability-report-2022-en.pdf

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. This includes oversight of our Climate Transition Plan and net-zero ambition by 2050, as well as other climate-related targets such as our operational GHG reduction target. The Risk Management Committee (RMC) supervises key frameworks related to CIBC's principal business risks, which include climate-related risks. The RMC reviews reports related to climate-related scenario analysis and our approach to identifying and managing climate-related credit risks through the development of a carbon scoring methodology. [...] Environmental Risk is part of Enterprise Risk Management which provides independent oversight of the identification, measurement, monitoring and control of climate-related risks and ensuring climate considerations are incorporated into risk frameworks, policies and risk appetite.

https://www.cibc.com/content/dam/cibc-public-assets/about-cibc/corporate-responsibility/environment/documents/cibc-cdp-climate-change-response-2022-en.pdf

CIBC has an established climate governance structure as part of an overall ESG governance framework that drives accountability and supports alignment of climate-related activities across the enterprise. This framework allocates responsibility for our ESG strategy, including our climate-related activities, among the Board of Directors, senior executive management, and strategic business units and functional groups. This framework also allows for monitoring, evaluating and responding to risks and opportunities posed by climate change. Our approach to climate governance is to support the ongoing advancement of our climate-related priorities across our bank, by outlining where responsibility lies and the distinct roles that different Board committees and management-level business functions play in providing oversight and decision-making on climate-related risks and opportunities to support our net-zero ambition. [...] The Board is responsible for the oversight of CIBC's strategic plans and priorities. In fulfilling this responsibility, the Board considers CIBC's purpose and ESG strategy in our business operations and decision-making. The specific oversight of our ESG strategy, which includes our climate strategy and net-zero ambition, is led by the Corporate Governance Committee (CGC). Board committees provide oversight on specific components of our ESG strategy, which includes our climate strategy and ESG governance based on respective committee mandates. [...] The Corporate Governance Committee (CGC) oversees ESG strategy, including climate strategy and net-zero ambition, ESG governance, as well as climate-related disclosure and stakeholder engagement practices. To support its oversight responsibilities, it has dedicated ESG agenda time and receives quarterly updates which include climate-related information, such as progress towards net-zero targets, stakeholder expectations, regulatory developments and implications, insights from CIBC's participation in climate-related industry forums and business activities, including from regions across CIBC's global footprint. It receives a quarterly summary of other committees' ESG-related updates, including those related to climate, in its quarterly reporting to support coordination and alignment across the entire Board. [...] The Risk Management Committee (RMC) has oversight responsibilities including defining CIBC's risk appetite, reviewing and approving key frameworks and policies to identify and control principal risks, as well as overseeing the identification, measurement, monitoring and mitigation of CIBC's principal business risks, including climate-related risks. It receives regular climate-related risk updates through quarterly risk reports as well as annual portfolio and risk reviews. Climate-related risks are also addressed in risk appetite statements and considered in stress tests. [...] The Audit Committee oversees the establishment and management's maintenance of a system of processes and controls to ensure the integrity, accuracy and reliability of ESG disclosures in the Annual Report, the Sustainability Report, and other material ESG disclosure documents, such as this Climate Report. This supports the appropriateness and accuracy of material ESG disclosures, which include climate-related disclosures, so that information presented is not misleading. To support its oversight, it receives periodic updates on emerging ESG disclosure standards and regulations. [...] The Management Resources and Compensation Committee (MRCC) oversees CIBC's human capital strategy, including compensation and alignment with CIBC's strategy. It assesses the alignment of executive and employees' ESG performance goals with compensation based on the ESG Index, which includes climate-specific key performance indicators, and forms part of our Business Performance Factor (BPF).

https://www.cibc.com/content/dam/about_cibc/corporate_responsibility/pdfs/climate-report-2023-en.pdf

Our climate governance structure, which forms part of our Environmental, Social, and Governance (ESG) governance framework, supports the effective oversight, management and execution of our net-zero ambition. The summary below demonstrates how our net-zero targets are governed and operationalized across the enterprise. More information about our ESG governance framework [can be found in our 2024 Management Proxy Circular, 2023 Sustainability Report and 2023 Climate Report.](https://www.cibc.com/en/about-cibc/investor-relations/annual-reports-and-proxy-circulars.html)

#### CIBC Board of Directors

- Our Board's Corporate Governance Committee leads oversight of CIBC's net-zero ambition, climate strategy and broader

ESG strategy, including how the enterprise is measuring, evaluating and monitoring progress against our strategic goals.
Other Board committees oversee the execution of specific components of our ESG strategy, which includes our climate strategy,
and ESG governance based on respective mandates.

#### Executive Committee and Senior Executive ESG Council

- Our Executive Committee is accountable for the advancement of CIBC's ESG agenda and is responsible for management and

decision-making around our net-zero efforts and progress, including approving our interim net-zero targets. Accountability for
leading and coordinating our climate strategy is held with our Executive Vice-President and Chief Legal Officer (EVP and CLO),
as the horizontal owner of ESG across the enterprise. Our Senior Executive Vice-President and Chief Risk Officer also plays a
critical function as the executive accountable for initiatives that manage climate risk.

- Our Senior Executive ESG Council, chaired by our EVP and CLO, is comprised of Executive and Senior Vice Presidents from

across the banks, and supports the coordination of ESG activities across CIBC, including our net-zero by 2050 ambition.

#### Governance and execution support

- Our Enterprise ESG team facilitates the execution of CIBC's climate strategy and net-zero ambition, which is delivered

through strategic business units and functional groups. Our Global Operational and Enterprise Risk Management function,
which includes a dedicated Environmental Risk team, also works alongside other teams to advance CIBC's net-zero ambition,
including regularly monitoring and assessing progress and measuring our financed emissions on an annual basis.

- Our Strategic Business Units and functional groups are engaged in ESG activities and will be responsible for accelerating and

incorporating climate action into business strategy and execution as applicable.

https://www.cibc.com/content/dam/about_cibc/corporate_responsibility/pdfs/net-zero-approach-2024-en.pdf

**Responsible Investment Committee**

CIBC AM has established a Responsible Investment Committee (RIC) consisting of our executive leadership team, including the Chief Executive Officer, and complemented with subject matter experts across relevant business units. The RIC is responsible for the following:

- **Reviewing and approving climate change policy: The RIC reviews and approves CIBC AM's climate change policy, which** outlines our approach to addressing climate risks within our investment portfolios.

- **Overseeing the implementation of climate change strategies: The RIC oversees the implementation of CIBC AM's climate** change policy.

- **Monitoring performance: The RIC monitors the risks and opportunities identified in annual Taskforce for Climate-related** Financial Disclosures (TCFD) reporting and ad hoc reporting on climate related risks.

- **Reporting on progress: The RIC oversees and approves reporting on our approach to climate change, including annual TCFD** and ESG and stewardship reporting.

**Portfolio Management and Research**

The Portfolio Management and Research team is responsible for implementing the strategies outlined in CIBC AM's climate change policy that are approved by the RIC. The team works with the firm's sustainable investing professionals to conduct climate-risk assessments, identify opportunities, engage with portfolio companies, and integrate climate considerations into the investment process across various asset classes.

**Total Investment Solutions**

The Total Investment Solutions (TIS) team is responsible for integrating climate-related considerations into the selection and monitoring of our external sub-advisors. The team works in collaboration with our sustainable investment professionals to conduct regular assessments of our external managers' approach to ESG and climate integration throughout their investment process. We focus on engagement and work directly with our managers to highlight the importance of the robust integration of ESG and climate risks and opportunities within their investment process. The TIS team is also responsible for the oversight of our managed solutions platform and evaluation of climate impacts on strategic asset allocation and manager selection and fulfillment decisions.

**Responsible Investing Working Group**

The Responsible Investing Working Group (RIWG) is comprised of members from various functional groups at CIBC AM, and serves as the primary group for actioning RIC proposals. As part of its mandate, the RIWG drafted the CIBC AM climate policy, and is working toward further implementation actions for the effective monitoring of climate risks across the organization.

https://www.cibc.com/content/dam/cibc-public-assets/asset-management/pdfs/climate-report-en.pdf

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]To ensure alignment with our broader ESG strategy and emerging stakeholder priorities, there is 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.

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. This includes oversight of our Climate Transition Plan and net-zero ambition by 2050, as well as other climate-related targets such as our operational GHG reduction target. The Risk Management Committee (RMC) supervises key frameworks related to CIBC's principal business risks, which include climate-related risks. The RMC reviews reports related to climate-related scenario analysis and our approach to identifying and managing climate-related credit risks through the development of a carbon scoring methodology.

At the executive management level, our Executive Committee is accountable for the progress of CIBC's ESG agenda, and our President and Chief Executive Officer (CEO) is responsible for setting the right tone company-wide and establishing our ESG priorities. The Senior Executive Vice-President and Chief Risk Officer (SEVP and CRO) has overall responsibility for identifying, assessing and managing climate-related impacts on CIBC. The CRO works closely with our Executive Vice-President and Chief Legal Officer (EVP and CLO) who is the executive horizontal owner of ESG across the enterprise, including overseeing our climate strategy, which is a key component of CIBC's ESG Strategy. In 2021, we formed a Senior Executive ESG Council to champion CIBC's refocused ESG strategy and to augment ESG governance at the executive management and decision-making level.

Environmental Risk is part of Enterprise Risk Management which provides independent oversight of the identification, measurement, monitoring and control of climate-related risks and ensuring climate considerations are incorporated into risk frameworks, policies and risk appetite.

An Enterprise ESG team, led by the VP, Enterprise ESG, works alongside other teams and ESG experts across the bank, such as Enterprise Risk, to advance CIBC's ESG agenda, and ensure that climate-related risks and opportunities are integrated into the enterprise ESG strategy.

CDP Questionnaire Response 2022

Attach commitment or position statement(s)[…]CIBC Sustainability Report 2021 [attached], page 16:
Addressing climate change and meeting the commitments made under the Paris Agreement, specifically to limit temperature rise to 1.5°C above preindustrial levels, requires a collective effort on a global scale. Currently, the world is not on track to meet the Paris Agreement.

At COP26 in late 2021, we saw clear momentum and widespread recognition that more urgent action is critical. However, the challenge is complex and can only be tackled through government, industry and community collaboration.

CIBC is committed to doing its part in achieving a lower-carbon economy. This includes supporting our clients, helping to address the most acutely needed solutions including the need for carbon reduction strategies and scaling renewable energy development, and providing market perspectives to policy-makers on the levers needed to unlock finance to assist with this transition.

There must also be global recognition for the distinct country-specific considerations and challenges each nation faces in the pursuit of tackling climate change which means increased investments in technology and innovation are needed to support decarbonization.

Recognizing the work ahead, in 2021, CIBC announced a Climate Transition Plan that included a net-zero ambition [attached] for our operational and financing activities by 2050. This plan builds on our climate action efforts, and it was informed through engagements with clients, investors, government, regulators and team members. It will help guide our path forward amidst this evolving landscape.

CDP Questionnaire Response 2022