Complaints Handling Policy

(Composed Finance (the “Firm”)

Goals

Ensure the fair and free treatment of complaints received by the FIRM regarding the products it distributes and the services it offers.

Explain the complaints review process established by the CABINET and the process for resolving any dispute that may remain following the handling of a complaint. 

Scope of application

This policy applies to the FIRM, its directors, its officers, its employees and its advisors who carry out their activities in Quebec.

Definition of a complaint

Under this policy, a complaint is any statement from a client that expresses a dispute involving the FIRM, the conduct and/or actions of an advisor. It must consist of one of the following three elements:

A complaint against the CABINET or an advisor;

Identification of potential or actual harm to the complainant (loss of rights);

The claim for a corrective measure (cancellation of a contract, reimbursement, compensation, etc.).

Typically, a complaint is made in writing and reported by letter, email, fax, or other form that allows for its retention. If a customer makes a complaint by telephone or in person, the person receiving the complaint must document the facts alleged in detail and in a manner that allows for its retention.

An initial expression of dissatisfaction on the part of a client, whether written or not, does not constitute a complaint if it is resolved in the normal course of the FIRM’s activities. 

Appointment of a person responsible for handling complaints and resolving disputes 

The FIRM must designate a person responsible for handling complaints (Jonathan Beaulieu) whose main function is to ensure that complaints received by the FIRM are handled in accordance with this policy.

The person responsible for handling complaints may delegate the handling of certain complaints to a person who will respond for them and on their behalf. 

The person responsible for handling complaints also acts as a respondent to the various regulatory bodies to which the FIRM is subject in matters of handling complaints and settling disputes.

Receiving a complaint

Any advisor or employee receiving a complaint from a client must forward it, upon receipt, to the person responsible for handling complaints.

The person responsible for handling complaints acknowledges receipt of the complaint within 2 working days. 

The acknowledgement of receipt (see model Annex 1) must contain in particular the following elements:

• The name and contact details of the person responsible for handling the complaint;
• A description of the FIRM’S internal complaints handling process, including usual timeframes for responding to a complaint;
• The person responsible for handling complaints may make a request for additional information to which the complainant must respond within 7 days, failing which his complaint will be deemed abandoned.
• The person responsible for handling complaints must notify the insurer if his or her cooperation is required to resolve a complaint relating to a product or service offered by the insurer or if this complaint may have consequences on the reputation of the insurer or its relations with the complainant. In such a case, the person responsible for handling complaints will cooperate with the insurer to resolve the dispute.

Handling a complaint

Each complaint must be subject to a thorough analysis of the facts specific to each case. The person responsible for handling complaints will gather the facts concerning the complaint impartially from all parties concerned. 

The person responsible for processing complaints shall send the complainant a written and reasoned response within 14 days of receiving all the information necessary for processing the complaint.

In the event that a period of 14 days has elapsed since receipt of the complaint without a written and reasoned response having been sent to the complainant, the person responsible for processing complaints shall send the complainant a notice informing him of the progress of the file, the reasons for the delay and shall set a new deadline for the transmission of the response.

Contents of a complaint file

Each complaint file must be a separate file and include the following elements: 

The written complaint and all documents transmitted to the complainant;

The result of the complaint handling process (the analysis and related documents);

A copy of the decision of the complaints officer, written and reasoned, which was sent to the complainant.

Transferring the file

If the complainant is not satisfied with the outcome of the handling of his complaint or with the handling of the complaint itself, he may request the transfer of his complaint file to the Financial Markets Authority.

This right may only be exercised by the complainant upon expiry of the period provided for obtaining a final response, without exceeding a period of one year from the date of receipt of this response.

The transferred file is made up of all the documents relating to the complaint.

Complaints register

Documentation relating to a complaint file must be kept on any medium that ensures accessibility and the maintenance of its integrity.  

Each complaint must be recorded in the Complaints Register, which must contain the following information:

• The complaint file number;
• The date of opening and closing of the complaint file;
• The name of the complainant;
• The type of financial product;
• The nature of the complaint (reasons);
• The number of the contract(s) covered by the complaint;
• The name of the representative to whom the complaint relates;
• The outcome and date of the decision rendered by the Complaints Officer with regard to the complaint;
• Transfer of the file to the Financial Markets Authority.

• Reporting of complaints

The complaints officer must submit the reports required by the Financial Markets Authority.

Policy Review

The Policy must be reviewed periodically. In addition, whenever significant legislative or regulatory changes affecting the FIRM are made, the Policy must be amended accordingly.

Entry into force

This policy is effective as of 03/29/2021

Annex 1 

(Quebec)

ACKNOWLEDGMENT OF RECEIPT TEMPLATE

Including the notice

DATE

COMPLAINANT’S CONTACT DETAILS 

SUBJECT: (Complaint file number)

Madam, Sir,

We acknowledge receipt of your complaint received at our offices on XXX

The investigation of your complaint has been entrusted to the complaints officer. You can contact (name XXX), at the following address and telephone number: (indicate the contact details of the complaints officer).

NOTICE

In accordance with our Complaints and Dispute Resolution Policy, we will provide you with our final response regarding your complaint received on XX, in writing, within XX days (complaint processing period set out in the policy). In the meantime, we may need to contact you to obtain additional information. 

If you are dissatisfied with the process for examining your complaint or the outcome of this examination, you may request that your file be transferred to the Autorité des marchés financiers.

Following the transfer of your file, the Financial Markets Authority will proceed to analyze it and propose dispute resolution services, if it deems it appropriate. 

Finally, please note that the transfer of your file to the Financial Markets Authority does not interrupt the limitation period for your appeals before the civil law courts. 

For your information, please find attached a copy of our Complaints Handling and Dispute Resolution Policy.