CIBC Fixed Income Pre-Hedging Disclosure

Pre-Trade Position and Pre-Hedging

When a client indicates an interest in a potential transaction or provides CIBC with a request to enter into a transaction, CIBC may use that information to engage in pre-hedging and hedging activities. This may include entering into transactions prior to executing the client’s potential transaction in order to facilitate the client’s potential transaction. Any transaction entered into by CIBC with a view to facilitating the client’s potential transaction (i) will be entered into by CIBC as principal, not as agent for the client, (ii) could be at different prices from the price at which CIBC executes the client’s transaction, (iii) may affect the market price of or liquidity for the products the client is buying and/or selling and (iv) may result in profit, or loss, to CIBC. At all times, the pre-hedging and hedging activities will be for risk management purposes and execution optimization only and will not be conducted with the intention to adversely affect the client’s potential transaction, although these activities may have such unintended consequences. Any such pre-hedging and hedging activities will occur in compliance with applicable local laws, rules, and regulations.