Canadian Imperial Bank of Commerce (CIBC)

InfluenceMap Score
for Sustainable Finance Policy Engagement
Performance Band
Organization Score
Relationship Score

Toronto, Canada
Official Web Site:

Sustainable Finance Lobbying Overview: CIBC’s engagement on sustainable finance policy is somewhat unclear, although it appears to be involved in the development of Canada’s transition taxonomy, and has engaged on climate disclosure and risk management policies.

Top-Line Messaging on Sustainable Finance Policy: In its 2022 Climate Report, CIBC stated support for action to keep global temperature rise to 1.5C, and CEO Victor Dodig has supported urgent action to tackle climate change. CIBC has stated that it is engaging with policymakers to develop a “robust sustainable finance market.”

Position on Regulated Corporate ESG Disclosure: In its 2022 CDP response, CIBC stated that it supported, with minor exceptions, the Canadian Office of the Superintendent of Financial Institutions’ (OSFI) efforts to mandate climate-related financial disclosures. In February 2022, CIBC submitted a comment on the Canadian Securities Administrators’ (CSA) proposed climate disclosure rules, but did not take a clear position on the rules, stating that it had provided input into the response submitted by the Canadian Bankers Association. In its 2022 Climate Report, CIBC stated it was monitoring climate disclosure proposals at the SEC and ISSB but did not take a clear position on these policies. A commenter who reported affiliation with CIBC Wealth Management opposed the SEC’s climate disclosure rule in a March 2022 comment.

Position on a Taxonomy: In its 2022 Climate Report CIBC reported engaging with policymakers on the development of a “green” and “transition” taxonomy to achieve the goals of the Paris Agreement, although details of this engagement and the taxonomy are unclear.

Position on Incorporating ESG Factors Into Investor Duties: In 2020 and 2021 CIBC signed onto joint letters, first opposing Trump-era Department of Labor rules that sought to limit ESG investing, then supporting Biden-era rules that reversed the earlier rules and permitted the use of ESG factors in fiduciaries’ decision making.

Position on Incorporating ESG Factors Into Risk Management/Prudential Regulation: In its 2022 CDP response CIBC said that is supported, with minor exceptions, the OSFI’s “climate sensitive” prudential framework.

Industry Association Governance: CIBC has not disclosed a list of its industry association membership or engagement activities.

Strength of Relationship

How to Read our Relationship Score Map

In this section, we depict graphically the relationships the corporation has with trade associations, federations, advocacy groups and other third parties who may be acting on their behalf to influence climate change policy. Each of the columns above represents one relationship the corporation appears to have with such a third party. In these columns, the top, dark section represents the strength of the relationship the corporation has with the influencer. For example if a corporation's senior executive also held a key role in the trade association, we would deem this to be a strong relationship and it would be on the far left of the chart above, with the weaker ones to the right. Click on these grey shaded upper sections for details of these relationships. The middle section contains a link to the organization score details of the influencer concerned, so you can see the details of its climate change policy influence. Click on the middle sections for for details of the trade associations. The lower section contains the organization score of that influencer, the lower the more negatively it is influencing climate policy.