Purpose of the policy

The purpose of this policy is to provide a framework for handling complaints and resolving disputes. In particular, she is responsible for receiving and managing complaints for GROUPE FINANCIER SIGNATURE Inc. (GFS), as well as the transmission of such complaints and the preparation of reports to the Autorité des Marchés Financiers (hereinafter “AMF”).

Implementation of the policy

GFS is responsible for the implementation of this policy.
GFS is a guarantor to the AMF and, where appropriate, ensures that its staff is trained in the handling of complaints and the resolution of disputes. It ensures that this policy is communicated to staff and that they have all the tools necessary for its application. It also ensures that all of its obligations are met.

Complaint

For the purposes of this policy, the following elements constitute a complaint

• A reproach against GFS by a complainant;

• The identification by a complainant of a harm, potential or actual, that a consumer has suffered or could suffer through the fault of GFS

• A complainant’s claim for corrective action or redress.

However, the following does not constitute a complaint:

• An informal approach to correcting a particular problem to the extent that the

   issue is addressed as part of GFS’s regular operations without the 

   has not filed a complaint;

If the consumer or complainant’s manifestation does not meet the definition of a complaint set out above, the steps that GFS may take to transfer the complaint to the relevant person or entity shall not be construed as being subject to this policy. The same applies when GFS compiles a case with regard to the said event.

As GFS has business relationships with many players in the field, it has the interest to undertake internal or external investigations to verify whether it wishes to maintain its business relationships with certain actors who could be the subject of a demonstration or a complaint.

Administrative Process

Any manifestation by a complainant or a consumer meeting the definition of complaint mentioned above must follow the process.

Receipt of complaint

Complainants who wish to file a complaint are invited to do so in writing to the attention of the Chief Compliance Officer
Daniel Rouillard
83 rue Champlain, Salaberry-de-Valleyfield, QC, J6T 1W4
or

[email protected]

or

Phone: 450-747-4711 ext. 110

In the event that the complaint is made to a GFS employee, the employee has the obligation to transmit it, without delay, to GFS for the implementation of this policy.
In the event that the complaint is made verbally, it must be summarized on paper by the person receiving the said verbal complaint.
Following receipt of the complaint by GFS, an acknowledgement of receipt is provided to the complainant containing the following information:
• A summary of the complaint, including the nature of the complaint,
the alleged harm and the remedies or remedies
claimed by the complainant;
• GFS’s name and contact information;
• The information that GFS lacks to carry out adequate monitoring
the complaint;
• The time limit for the complainant to provide the missing information
and a notice that, in the absence of such additional information, the
complaint will be deemed abandoned;
• Copy of this Complaints and Complaints Policy
dispute resolution;
• A notice informing the complainant of his or her right to request the transfer
of his file with the AMF in the event of his dissatisfaction with the final position
GFS or dissatisfaction with the handling of the complaint;
• A notice to the complainant that the AMF may offer, when it deems it
a dispute resolution service;
• A statement informing the complainant that the filing with GFS or
the AMF does not interrupt the limitation period for civil actions
to which the consumer or complainant would be entitled.

Opening the complaint file

Each complaint referred to GFS is dealt with separately in a separate file. Upon receipt of the complaint, a file is opened containing the following elements:
• Copy of the written complaint;
• In the case of an oral complaint, a copy of the summary of the complaint made by the person who received the oral complaint;
• A complaint sheet, summarizing the nature of the complaint:
• The reproach against GFS;
• The alleged damage;
• The corrective measure or remedy requested.
• The outcome of the complaint process, analysis and documents
Relevant;
• The final response to the consumer, written and motivated.

Complaint process

Within 10 days of receipt of the complaint by GFS, GFS must ensure that the acknowledgement of receipt provided for in this policy is sent to the complainant.
The company ensures that the complaint has been addressed and that its final response has been forwarded to the consumer by the later of the following two deadlines:
• Within 30 days of the acknowledgement of receipt being sent; or
• Within 30 days of receipt of the additional information required in the
the acknowledgement of receipt.
However, in the event that the complaint raises complex issues or requires a lengthy process, rather than the final response, the designated person may ensure that a notice is sent to the consumer outlining the progress of the complaint and the additional time required.

The complaints process is as follows:

Upon receipt of the complaint, GFS chooses to handle the case itself or to delegate the handling of the case to an employee. This choice, and the name of the delegate if applicable, is indicated on the complaint form on file.
Whether GFS handles the complaint itself or delegates it, it must ensure that an acknowledgement of receipt has been sent to the complainant within 30 days of its receipt by the designated person.

Analysis:

The person analyzing the complaint first determines whether the complaint will require substantial work. If necessary, the Commission must send a notice to the complainant informing him or her of the time frame within which the complaint is expected to be dealt with according to his or her estimate and the status of the analysis of the complaint. Such an opinion must be reasoned and placed in the complaint file. Depending on the importance, seriousness or any other aspect specific to the complaint, such a notice may be sent more than once for the same complaint.
The person analysing the complaint must read the complaint and try to obtain the version of the person who is the subject of the complaint within a reasonable time. It must also analyze the relevant documents of which it has or can obtain a copy within a reasonable time. The Commission must document its analysis and keep relevant documents on file with the complaint.
Once the analysis is complete, the person handling the complaint must draw up his or her working hypotheses.
These working assumptions are not part of the complaint file.

Answer:

If the person who analyzed the complaint is not the designated person, he or she submits his or her working hypotheses to the designated person. The designated person takes note of the working hypotheses and proceeds to write the answer.
The response must be in writing and reasoned. It must be placed on the complaint file. If the answer is final, it must be indicated. A final response must contain a statement informing the complainant of his or her right to request the transfer of his or her file to the AMF in the event of dissatisfaction with GFS’s final position or dissatisfaction with the handling of his or her complaint. The said statement must also indicate to the complainant the procedure to be followed in order to request such a transfer.
If the response is not final, it must indicate to the client the actions they can or must take with GFS in order to obtain a final response.

Forwarding of the complaint to the AMF

If the complainant wishes to exercise his or her right to have the complaint transferred to the AMF, he or she must inform the Chief Compliance Officer.