FAQs (frequently asked questions)

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1 FAQs (frequently asked questions) about the CIBC Asset Management Personal Trading Policy CONTACTING WEALTH MANAGEMENT COMPLIANCE ( we, us, and our ) I have a question about the Policy, a trade pre approval request or some other matter. How can I contact Wealth Management Compliance? To ensure the quickest reply, all inquiries should be sent by to the Compliance Personal Trading Mailbox. If you are sending the message from an external account, the complete address is: Mailbox.Compliance We monitor the mailbox during TSX market hours (9:00 a.m. 4:00 p.m. ET). We do our very best to respond within one hour, but it may take longer depending on volumes and the nature of your inquiry. The mailing address for Wealth Management Compliance is as follows: CIBC Wealth Management Compliance 25 King Street West, CCN 23rd Floor Toronto ON M5L 1A2 WHO IS COVERED UNDER THE POLICY? I share a household with a spouse and/or other family members. Why are they subject to the Policy? As a Covered Person, you are deemed to have a beneficial interest in the investment accounts held by a spouse or other family members who live in the same household. These are considered Covered Person Accounts under the Policy. The accounts of your spouse or other family members are subject to trade pre approval and account monitoring, similar to your own individual accounts. While CIBC cannot require Covered Person Accounts held by a spouse or other family members be maintained at a CIBC dealer, they are strongly encouraged to do so. I am a temporary or contract employee. Am I still subject to the Policy? Yes. A Covered Person under the Policy includes ALL employees, whether they are full time, part time, contract or otherwise. I am on a leave of absence (maternity, long term disability, personal leave, etc.). Am I still subject to the Policy? Yes. However, we may consider approving an exemption from trade pre approval requirements during your leave. Send an to the Compliance Personal Trading Mailbox with the details of your particular situation. Reviewed: September 2015 Page 1 of 5

2 INVESTMENT ACCOUNT MONITORING How do I transfer my accounts held with an outside dealer to CIBC? You can contact a licensed advisor from the Employee Financial Services Centre at , confidentially and at your convenience, to help you determine which services and account types are appropriate for your circumstances. How long does it take to transfer an account? This will depend on the type of account and the holdings that are being transferred. For new hires, investment accounts with other dealers must be transferred to CIBC within 90 days of your start date. We recommend you begin this process as soon as possible. What is a fully managed or discretionary account? In a fully managed/discretionary account, full investment discretion has been granted to a qualified investment advisor, portfolio manager or trustee. Neither the employee nor the employee s spouse, nor a family member residing with the employee, participates in the investment decisions or is informed in advance of transactions in the account. Fully managed/discretionary accounts are Exempt Covered Person Accounts under the Policy. You are required to disclose these accounts and provide written confirmation from the manager of the account that no investment instructions will be taken from the Covered Person as well as a copy of the fully managed account agreement. These accounts are not subject to trade pre approval requirements or ongoing monitoring by Wealth Management Compliance once this written confirmation and copy of the account agreement are reviewed by us. I have a CIBC Employee Share Purchase Plan (ESPP) account with Solium. Is this an Exempt Covered Person Account? Yes. Trade pre approval employee share purchase and stock option plan accounts are Exempt Covered Person Accounts under the Policy. You are not required to disclose these accounts and they are not subject to monitoring by Wealth Management Compliance. Trade pre approval for the sale of shares in these accounts is required, unless they are considered an Exempt Investment under the Policy. Securities issued by CIBC are considered Exempt Investments under the Policy because CIBC is a constituent of the S&P/TSX 60 Index. As such, trades of CIBC securities held in your ESPP account are not subject to pre approval requirements. I have an account that can only hold GICs and/or mutual funds. Do I need to disclose this account and move it to a CIBC dealer? Accounts that can only hold deposits or GICs issued by a financial institution or mutual funds are not required to be disclosed and do not need to be transferred to a CIBC dealer. If it is possible to hold equities and fixed income securities in your account, whether you actually hold them or not, then the account must be disclosed and transferred to a CIBC dealer. I have Covered Person Accounts held with dealers outside of CIBC, either for my spouse or family member or for the purpose of trading futures and foreign currencies, which have been disclosed to Wealth Management Compliance. What else do I need to do? You must arrange for us to receive duplicate trade confirmations and monthly account statements (see CONTACTING WEALTH MANAGEMENT COMPLIANCE at the beginning of this FAQ). Reviewed: September 2015 Page 2 of 5

3 Do my Covered Person Accounts have to be coded PRO? Covered Person Accounts are generally not required to be coded PRO, unless your spouse or a family member residing with you is employed by a securities dealer. However, if you work in a CIBC group that supports an IIROC dealer member or are registered as a Portfolio Manager or an Investment Fund Manager, you are required to have your accounts coded PRO. If you require further clarification, please speak to your reporting manager. Does an employee s spouse have to transfer his/her account to a CIBC dealer? No. CIBC does not require a spouse or other family members residing with you to maintain their trading accounts at CIBC. However, we strongly encourage them to do so. If a spouse or family member declines to maintain their account(s) at CIBC, Wealth Management Compliance must be informed in writing. For monitoring of these outside accounts, you must arrange for us to receive duplicate trade confirmations and monthly account statements (see CONTACTING WEALTH MANAGEMENT COMPLIANCE at the beginning of this FAQ). I want to trade in futures and foreign currencies. Since a CIBC dealer does not offer these services, can I open an account with an outside dealer? Yes, you are allowed to maintain accounts with an outside dealer for the purpose of holding/trading futures and/or currencies. You must provide written confirmation to Wealth Management Compliance that the account can ONLY hold/trade futures and/or currencies. For monitoring purposes, you must arrange for us to receive duplicate trade confirmations and monthly account statements (see CONTACTING WEALTH MANAGEMENT COMPLIANCE at the beginning of this FAQ). TRADE PRE APPROVAL REQUESTS How do I know if a security is an index constituent and considered an Exempt Investment under the Policy? Securities of all issuers listed on the S&P/TSX 60 Index, the S&P 100 Index and the S&P Global 100 Index are Exempt Investments. You are not required to seek trade pre approval for Exempt Investments. When selling Exempt Investments, the 15 day (calendar day) hold period still applies. S&P Dow Jones Indices and other index providers often require subscription access to obtain a complete list of index constituents. Remember that constituents within these indices will change from time to time. If you are uncertain whether the security you want to trade is an Exempt Investment, it is a good idea to submit the trade for pre approval anyway. I submitted a trade pre approval request and it was denied. When will I be allowed to trade it? A request will be approved if the security has not been traded in a CIBC portfolio within the last 3 trading days. If your request is denied, you will be advised of the earliest date to submit another request for pre approval. Once resubmitted, we will once again check if the security has been traded in the most recent 3 trading days in order to approve or deny your request. Reviewed: September 2015 Page 3 of 5

4 I have submitted multiple trade pre approval requests for a particular security and all have been denied. Will you consider giving me an exception to the Policy? We will not consider exception requests for purchases of securities under any circumstances. We will consider exception requests for sales of securities if you have experienced a price decline of more than 20% from your original purchase price. We will also consider exception requests in situations of financial hardship or other extraordinary circumstances. For consideration of an exception, send an to the Compliance Personal Trading Mailbox with the Trade Pre Approval Form and any relevant details regarding your particular situation. I received pre approval for a trading request, but I didn t execute the trade. Can I make the trade at a later time? Trade pre approvals are given for the same trading day on which your request was made. The approval does not extend beyond that day. If you choose not to execute your trade as approved and wish to place the same trade at another time, you must submit another request for our approval. Are there any restrictions on buying and selling securities issued by CIBC? That depends. As a constituent of the S&P/TSX 60 Index, securities issued by CIBC are considered Exempt Investments under the Policy and are not subject to trade pre approval requirements. Short selling and options trading on securities issued by CIBC are prohibited. It is your responsibility to determine if you are subject to any additional trading restrictions relating to the purchase or sale of securities issued by CIBC. The Employee Stock Trading Schedule can be found on CIBC Today. Do I need to obtain pre approval for trades of mutual funds, exchange traded funds (ETFs) or closed end funds? Mutual funds and ETFs are Exempt Investments under the Policy and are not subject to trade pre approval requirements. Non redeemable or closed end investment funds are not considered Exempt Investments under the Policy and trade pre approval is required. If you believe the security you wish to trade is an Exempt Investment, but aren t 100% certain, it is a good idea to submit the trade for pre approval anyway. Do I need to obtain pre approval for trades of foreign currencies and commodity futures? No. Is it necessary to obtain pre approval for an option assignment trade? That depends. You must obtain pre approval for the original option trade. Pre approval of an option assignment trade is not required as the Covered Person has no control over the exercise of the option and would only be notified of the assignment after it has taken place. Reviewed: September 2015 Page 4 of 5

5 Is it necessary to seek pre approval for an exercise of warrants? Yes. When a warrant is exercised, the Covered Person uses discretion and provides specific instructions. Pre approval is required. Is pre approval required for the transfer of CIBC shares from my ESPP account (Solium) to my CIBC dealer account? That depends. If the shares are being transferred to another personal account, beneficial ownership is not changing, a trade is not taking place so pre approval is not required. If the shares are being transferred to a joint account or an account registered in a different name, beneficial ownership is changing and trade pre approval is required. Can my spouse or investment advisor send in a trade request on my behalf? No. Since there are conditions on the trade request form which only the Covered Person can confirm, the trade request form must be signed, completed and submitted by the Covered Person. If I sell an Exempt Investment after I have held it for 15 calendar days, can I buy it back right away? Yes. Provided you meet any other applicable conditions of the Policy, there are no restrictions on when you can buy that security again. How does the 15 day hold period work? A security must be held for 15 calendar days before it can be sold. This includes Exempt Investments. If you bought a security on October 1 st, the earliest date you could sell the same security would be October 16 th. Do the representatives at CIBC Wood Gundy or CIBC Investor s Edge know about my trading restrictions? No. You are responsible to obtain all necessary approvals before placing a trade. Reviewed: September 2015 Page 5 of 5

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