We’re committed to responsible conduct in all our activities to:
- Protect and conserve the environment;
- Safeguard the interests of our stakeholders from unacceptable levels of environmental risk; and
- Support the principles of sustainable development.
We integrate these practices into our core business activities such as stakeholder engagement, facilities management, procurement and more through the principles of our Corporate Environmental Policy (PDF, 95 KB) Opens in a new window..
Policy implementation is the responsibility of the Environmental Risk Management group. This group engages with the bank's business and functional groups to facilitate policy and program implementation and best practices across the bank. In support of the CIBC Corporate Environmental Policy requirements, we’ve developed further requirements within our Environmentally Responsible Procurement Standard and the Environmental and Social Credit Risk Management Standards and Procedures.
Our due diligence process
Our Environmental Credit Risk Management group developed and proactively manages our Environmental and Social Credit Risk Management Standards and Procedures, which help employees identify environmental and related social risks pertaining to credit evaluation and financing. The standards require graduated levels of environmental and related social due diligence depending on the level of identified risk. CIBC’s Environmental Credit Risk Management group directly participates in the credit evaluation process by reviewing environmental and related social due diligence information in prescribed circumstances. In 2020, we completed specialized environmental and social due diligence reviews on 787 transactions totaling over $18 billion.
Our Global Reputation and Legal Risk Policy also requires that each credit transaction be examined for potential reputation and legal risks, including those of an environmental or a social nature. Transactions that may pose significant risk are escalated to the Reputation and Legal Risk Committee for senior executive review. For transactions flagged as having unacceptable environmental, social or governance risks, we engage with the company and require that they mitigate the risks as a condition of financing.
Pre-assessed environmental consultants
The Environmental Credit Risk Management group maintains a pre-assessed list of environmental consulting firms across Canada. This list identifies firms that meet our criteria in terms of expertise, quality of service and other standards when performing environmental site assessments and other third-party investigations.
We review environmental reports prepared by consulting firms as part of our transactional due diligence process. The Environmental Credit Risk Management group may invite consulting firms to apply to be added to our Pre-Assessed Environmental Consultant List when appropriate levels of reporting quality have been identified. We don’t formally endorse any specific environmental consulting firms. Consulting firms not on the list are in no way prohibited from providing environmental consulting services to CIBC clients.
Our lending approach
Our due diligence procedures include a review of environmental, social and governance considerations. Our loan approvals may include a review by our senior Reputation and Legal Risks Committee where reputation risk, along with transaction structuring is considered. Depending on the outcome of this review, CIBC may choose not to proceed with financing.
We will limit support for practices such as:
- The construction of new coal-fired power plants.
- Involvement in mountaintop removal mining of thermal coal.
- The practice of commercial whaling or the use of dynamite or poison in fishing activities.
- Activities exhibiting insufficiently strong mitigation of the degradation of protected critical natural habitats.
Furthermore, we won’t directly finance entities that:
- Show evidence of human rights abuses or evidence of modern slavery such as forced labour, human trafficking or child labour.
- Are involved in exploration or development related to oil and gas in the Arctic National Wildlife Refuge (ANWR).
- Directly relate to the trade-in or manufacture of equipment or material for the specific purpose of chemical, biological or nuclear weapons, land mines, or cluster munitions or directly deal with mining of conflict minerals.
- Manufacture or trade in activities deemed illegal under host-country laws or regulations.
- Are subject to economic trade and other government sanctions that would violate the laws of the country in which CIBC operates.
- Involve a business or individual engaged in activities inconsistent with accepted ethical behaviour in the community.
- Are directly in the business of unregulated internet gambling.
- Have operations or investments relating to or directly resulting in the transfer of equipment for international military (including internal security) operations where there is a risk of non-compliance with international law.
To complement our own policies, we’ve also been incorporating the Equator Principles into our environmental and social due diligence requirements since 2003. These principles are a voluntary financial industry benchmark for assessing and managing environmental and social risk in project financing. Our Environmental Credit Risk Management group reviews all Equator Principles-applicable transactions and provides training for lending and risk adjudication groups regarding compliance with the requirements of the Equator Principles. In 2020, this group reviewed 9 Equator Principles-applicable transactions that reached financial close.
Equator Principles Reporting (PDF, 100 KB) Opens in a new window.
Environmental Management System
The Environmental Risk Management group also maintains an Environmental Management System (EMS) that acts as the framework for the implementation of environmental policy requirements, including setting objectives and targets, monitoring progress and striving for continuous improvement. At CIBC, we use our best efforts to ensure compliance with relevant environmental laws and regulations. Our EMS is used to manage the risks and opportunities associated with our significant environmental aspects. It also addresses the bank’s credit business and procurement activities. A significant portion of our environmental data is managed by our service providers. As part of our service level agreements, service providers sign a statement of verification each year.
Our governance structure reflects our firm commitment to understanding and managing environmental, social and governance (ESG) issues, with oversight of climate-related risks and opportunities at both the Board and management levels.
At the highest governance level, two committees of the Board of Directors — the Risk Management Committee and Corporate Governance Committee — are charged with overseeing ESG matters, including climate change.
The Risk Management Committee assists the Board in fulfilling its responsibilities for defining CIBC’s risk appetite and overseeing the bank’s risk profile and performance against that criteria. This includes supervising key frameworks, policies and limits related to identifying, measuring, monitoring and controlling CIBC’s principal business risks — including climate-sensitive risk exposures.
The Corporate Governance Committee reviews disclosures on CIBC’s approach to conducting its business in an ethical, socially responsible and environmentally conscious manner. CIBC’s climate change program is reviewed by the committee on a quarterly basis.
Furthermore, an Environmental Management Committee, which includes senior-level executives from across the bank, is in place to provide input on environmental strategy and oversight of our environmental initiatives. The committee meets quarterly and is responsible for facilitating the coordination and implementation of environmental performance priorities across the bank.