Whistleblower Program

CIBC is committed to doing what’s right for our clients, for our communities and for one another.

CIBC's confidential Whistleblower Program is available for reporting (anonymously if desired) irregular business activities or wrongdoing that could put CIBC's integrity or reputation at risk, or that is otherwise reportable under applicable whistleblower legislation.

CIBC’s Whistleblower Program is available online and by phone and is facilitated by an independent, external third party supplier called ClearView Strategic Partners.

What to report to the Whistleblower Program

Examples of what to report to the Whistleblower Program include:

• Accounting, internal accounting controls, financial reporting or auditing matters. For example, manipulating or circumventing accounting or auditing controls or procedures and altering financial data
• Dishonesty or serious misconduct by CIBC team members. For example, pressuring or misleading clients, borrowing funds from clients and trading on insider information
• Fraudulent, corrupt or unlawful activity. For example, theft, forgery, altering documents or data, engaging in bribery, soliciting or accepting kickbacks or theft of data for financial gain
• Unauthorized access or disclosure of internal, confidential or restricted information about CIBC, its clients or suppliers
• Actual or potential retaliation as a result of reporting a concern, including to a government agency or body that regulates financial institutions, or a law enforcement agency

What not to report to the Whistleblower Program

Certain concerns are not handled by the Whistleblower Program. For example:

• Concerns or issues that don’t involve wrongdoing by CIBC, its team members or parties acting for or on behalf of CIBC, such as concerns about reasonable workplace, operational or business activities
• Ordinary client experience, product feature or account servicing issues, such as late fees, call waiting times, unintentional errors or account agreement terms
• Specific concerns that have been directly addressed by active or concluded litigation where CIBC is a party
• Concerns not reported in good faith

Options for raising and resolving concerns 

If you’re a CIBC team member:

• Speak with your people leader as a first point of contact 
• If your concern is about your people leader, or you are uncomfortable speaking to them, consider reaching out to your people leader’s leader 
• Contact the other established channels listed in the CIBC Code of Conduct (and other relevant CIBC policies and procedures) to report concerns at any time. For example: 

The Whistleblower Program can be used to report any irregular business activities or wrongdoing that could put CIBC’s integrity or reputation at risk, or that is otherwise reportable under applicable whistleblower legislation, by following the steps below.

How to report a concern using the Whistleblower Program

The CIBC Whistleblower Program can be accessed by web portal, phone hotline and mail:

• Web portal – visit the ClearView Connects website Opens a new window.. Select ”Submit a Report” and search for CIBC
• Phone hotline – dial

• Mail – contact the Chief Executive Officer, any member of the Executive Committee, or any member of the board by writing to the Corporate Secretary (81 Bay Street, CIBC Square, 20th Floor, Toronto, Ontario M5J 0E7)
  • Be sure to mark the envelope “Private and Confidential – Complaint” and note who the letter is addressed to

In addition to reporting internally to CIBC, individuals may also report to applicable regulators, governmental agencies, law enforcement agencies, or self-regulatory authorities in your jurisdiction. In Canada, this includes the Financial Consumer Agency of Canada Opens a new window. and the Office of the Superintendent of Financial Institutions Opens in a new window..

In all cases, please make sure that you:

• Share as much detailed information as possible — in addition to a clear description of the alleged wrongdoing, be sure to include all relevant names, job titles, dates, times and locations  
  • Effective investigation may not be possible where the information provided or available to CIBC is insufficient or vague
• Check back on the status of your report on the ClearView system as we may require additional information from you
  • The length of time to complete an investigation will vary based on the complexity of the concern reported and investigation required
• Don’t submit information that you know to be false, frivolous, embellished or vexatious 
  • Reporting a concern in bad faith constitutes a breach of the Whistleblower Policy
• Don’t submit multiple reports about the same matter or re-submit information already acknowledged as received
  • To follow up on the status of a previously submitted report, visit the ClearView Connects website Opens a new window.

What to expect when a concern is reported to the Whistleblower Program

• All information received by the Whistleblower Program is independently reviewed and, if applicable and within scope, assigned to an appropriate investigating team 
• Where possible, CIBC will acknowledge receipt of your report, request clarification or additional information if necessary and advise you when an investigation has been completed 
• The investigation process is objective and fair and outcomes are independently reviewed by the Whistleblower Program
• For confidentiality reasons, CIBC is unable to provide specific details about an investigation, including the outcome 
• CIBC takes steps to protect the anonymity of individuals, privacy, and the confidentiality of the concerns they report to CIBC
  • In certain cases, CIBC may be required to disclose information including the identity of an individual reporting a concern, or information that could reasonably be expected to reveal their identity, to a regulator or law enforcement agency, if such a disclosure is necessary for purposes related to an investigation. In addition, the regulator or law enforcement agency may in turn share the disclosed information with each other.

Prohibition against retaliation for raising concerns

No one at CIBC may suspend, discharge, discriminate against, harass or threaten, or otherwise retaliate against a team member or other person in any way for reporting an actual or possible misconduct in good faith, or as a result of providing information or participating in an investigation.