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WHISTLEBLOWER HOTLINE As a responsible business enterprise and corporate citizen, CIBC FirstCaribbean International Bank (CIBC FirstCaribbean) is committed to conducting its affairs to the highest standards of ethics, integrity, honesty, fairness and professionalism – in every respect, without exception, and at all times. CIBC FirstCaribbean takes its reputation very seriously and while reaching our business goals is critical to our success, equally important is the way we achieve them. . Our policy on fraud is one of zero tolerance. Therefore we will not tolerate acts by any director, officer, individual or group of individuals representing the bank, or engaged in activities on its behalf that are illegal, unethical, misrepresentative, or a violation of any regulation or established company policy. What to Report CIBC FirstCaribbean is responsible for and committed to providing accurate and reliable financial reporting. To support that goal, we have established this communication channel for employees and other stakeholders to report their concerns regarding the integrity of CIBC FirstCaribbean accounting, internal accounting controls or auditing matters. Employees may also use this communication channel to report concerns relating to ethical business or personal conduct, integrity and professionalism. This reporting system does not replace the other methods employees or other stakeholders have traditionally used to communicate with CIBC FirstCaribbean. You are encouraged to continue using our existing communication channels. How and Where to Report Reporting via Telephone (see special instruction for Bahamas, Cayman and Turks & Caicos below) Persons should call the dedicated Ethics Hotline operated by The Network Inc. using the numbers available in the chart below. The lines will be available on a 24 hour/365 days basis. Any calls made to the Ethics Hotline will be answered by trained interviewing staff and will be treated in strict confidence. The Network Inc. is an independent, third party supplier that has been selected to provide this confidential and anonymous communication channel for submitting your reports. Reporting via E-Mail CIBC FirstCaribbean employees and other stakeholders may also make disclosures by sending email to [email protected] 1 Reporting via Post Complaints in writing should be addressed to: The NETWORK 333 Research Court, Suite 100 Norcross, GA 30092 NB.: Other companies are also using this address for reports; you MUST indicate that the report relates to CIBC FirstCaribbean. Reporting via Fax Employees can also contact the Network via Fax to report their concerns using Fax # 770-409-5008. *Bahamas, Cayman Islands and Turks & Caicos employees are reminded to ONLY contact( via telephone, facsimile or email) the United States Whistleblower Hotline if you are reporting on another employee, contractor, vendor or persons affiliated with CIBC FirstCaribbean other than a customer. Contact the local hotline for all customer related reports. Ethics Hotline Telephone Numbers Instructions: First dial the access code, then following the prompt, dial the toll free number) Persons in countries from which it is necessary to call collect should remember that there is no caller ID engaged; therefore the operator cannot see the number from which you are calling. Also remember to state you are calling from CIBC FirstCaribbean when asked by the operator. Access Code Anguilla Antigua The Bahamas* - Us Hotline The Bahamas – Local Hotline – (Tel #: 242-356-6141) 1-800-872-2881 - Toll Free Number 866-252-1814 - Collect Call only 678-250-7589 678-250-7589 - 2 Barbados Belize British Virgin Islands Cayman Islands* Cayman Islands – Local Hotline – (Tel #: 345-9469545) Curacao Dominica Grenada Jamaica St. Lucia St. Kitts St. Maarten St. Vincent Turks and Caicos* Turks and Caicos – Local Hotline – (Tel #: 649-9413845) Trinidad and Tobago • 1-800-872-2881 1-800-872-2881 - 866-252-1814 866-252-1814 - 678-250-7589 678-250-7589 - 1-800-872-2881 - 866-252-1814 - 678-250-7589 678-250-7589 678-250-7589 678-250-7589 678-250-7589 678-250-7589 678-250-7589 678-250-7589 - 1-800-872-2881 866-252-1814 - Collect calling is a temporary measure and in no way erodes your ability to call anonymously. You Are Protected This reporting system is confidential and anonymous so you should feel comfortable using it. CIBC FirstCaribbean International Bank employees are protected against termination, demotion or any other adverse consequence to their employment when making a valid report. 3
