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”).

Policy implementation

GFS is responsible for implementing this policy.

GFS is a respondent to the AMF and ensures, where appropriate, that its staff are trained in handling complaints and settling disputes. It ensures that this policy is communicated to staff and that they have all the tools they need to apply it. It also ensures that it meets all its obligations.

Complaint

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

– A reproach levelled at GFS by a complainant;

– The identification by a complainant of potential or actual harm that a consumer has suffered or may suffer as a result of the fault of GFS

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

However, this does not constitute a complaint:

– An informal approach to correcting a particular problem, provided that the problem is dealt with as part of GFS’s regular activities, without the consumer having lodged a complaint;

If the consumer’s or complainant’s manifestation does not meet the above definition of a complaint, any steps GFS may take to transfer the complaint to the appropriate person or entity shall not be construed as being subject to this policy. The same applies when GFS builds up a file for the event in question.

As GFS has business ties with many players in the industry, it is in its interest to undertake internal or external investigations to verify whether it wishes to maintain its business relationships with certain players who may be the subject of a protest or complaint.

Administrative procedures

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

Receipt of complaint

Complainants wishing to file a complaint are invited to do so in writing, to the attention of the person designated to handle complaints, at the following address: [email protected]

In the event that the complaint is made to a GFS employee, the latter is obliged to forward it, without delay, to GFS for the application of the present policy.

If the complaint is made verbally, it must be summarized on paper by the person taking the verbal complaint.

Following receipt of the complaint by GFS, we ensure that an acknowledgement of receipt is sent to the complainant containing the following information:

– A summary of the complaint, explaining the nature of the complaint, the alleged harm and the corrective measures or remedies requested by the complainant;

– The name and contact details of GFS;

– The information that GFS lacks to adequately follow up on the complaint;

– The deadline for the complainant to provide the missing information and a notice stating that, failing this, the complaint will be deemed to have been abandoned;

– Copy of this Complaints and Dispute Resolution Policy;

– A notice 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 the final position of GFS or dissatisfaction with the handling of his or her complaint;

– A notice informing the complainant that the AMF may offer a dispute resolution service when it deems it appropriate;

– A statement informing the complainant that filing with GFS or the AMF does not interrupt the statute of limitations for civil remedies to which the consumer or complainant may be entitled.

Opening the complaint file

Each complaint sent to GFS is handled separately, in a separate file. As soon as the complaint is received, a file is opened containing the following information:

– Copy of 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 form, summarizing the nature of the complaint:

– The criticism of GFS;

– The alleged damage;

–The corrective action or adjustment requested.

– The outcome of the complaint handling process, analysis and relevant documents;

– The final response to the consumer, in writing and with reasons.

Complaint handling process

Within 10 days of receipt of the complaint by GFS, the latter 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 processed and that its final response has been sent to the consumer by the later of the following two deadlines:

– Within 30 days of dispatch of acknowledgement of receipt; or

– Within 30 days of receipt of the additional information requested in the acknowledgement of receipt.

However, if the complaint raises complex issues or requires extensive processing, rather than a final response, the designated person can ensure that a notice outlining the progress of the complaint and the additional time required is sent to the consumer.

The complaints handling process is as follows:

Upon receipt of the complaint, GFS chooses whether to handle the file itself or to delegate it to an employee. This choice, and the name of the delegated person if applicable, is indicated on the complaint form in the file.

Whether GFS handles the complaint itself or delegates it, it must ensure that an acknowledgement of receipt is sent to the complainant within 30 days of receipt by the designated person.

Analysis:

The person analyzing the complaint first determines whether it will require substantial work. If necessary, it must send a notice to the complainant informing him or her of the timeframe within which the complaint should be processed, according to the complainant’s estimate, and of the status of the complaint analysis. Such an opinion must be substantiated and placed in the complaint file. Depending on the importance, seriousness or any other aspect of the complaint, such a notice may be sent more than once for the same complaint.

The person analyzing the complaint must take cognizance of it and try, within a reasonable time, to obtain the version of the person who is the subject of the reproach. It must also analyze the relevant documents of which it has or can obtain a copy within a reasonable time. She must document her analysis and keep the relevant documents in the complaint file.

Once the analysis has been completed, the person handling the complaint must draw up his or her working hypotheses.

These working hypotheses are not part of the complaint file.

Answer:

If the person who analyzed the complaint is not the designated person, he or she hands over his or her working hypotheses to the designated person. The designated person takes note of the working hypotheses and proceeds to draft the answer.

The response must be in writing and must state the reasons on which it is based. It must be added to the complaint file. If the answer is final, this 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 the final position of GFS or dissatisfaction with the handling of his or her complaint. This notice must also tell the complainant how to request such a transfer.

If the response is not final, it must indicate to the customer what action he can or must take with GFS to obtain a final response.

Complaint forwarded to AMF

If the complainant wishes to avail himself of his right to have the complaint transferred to the AMF, he must inform the designated person in writing to the attention of the person designated to handle complaints, at the corresponding address below:

SIGNATURE FINANCIAL GROUP

83 rue Champlain

Salaberry-de-Valleyfield QC J6T 1W4

Transfer requests cannot be made verbally or by e-mail.

Upon receipt of a transfer request, the designated person forwards the complaint file to the AMF in accordance with the procedures established by the AMF. The transferred file is purged of personal information that is not relevant to the processing of the complaint, and of any working hypotheses that may be contained therein.