Purpose of the policy

The purpose of a complaint examination and dispute resolution policy is to set up a free and fair procedure for dealing with complaints. It is also intended to provide oversight for the receipt of complaints, delivery of the acknowledgment of receipt, creation of the complaint file, transfer of this file to the AMF and compilation of complaints for the purpose of preparing and filing reports twice a year to the AMF using the Complaint Reporting System (CRS).

Application

The present policy applies to all employees of AccèsConseil no matter the role or responsibilities they have.

Person in charge

The person in charge of applying the policy, Catherine Mainguy, President, acts as the respondent with the AMF and the complainant. This person trains the firm’s staff and provides them with the necessary information for compliance with the policy. Should this person be absent, she will designate someone else to be in charge which will be communicated at the appropriate time.

The person in charge is also responsible for:

• Delivering an acknowledgment of receipt;
• Delivering the required notices to the complainant;
• Transferring the file to the AMF, at the complainant’s request;
• Filing a report twice a year with the AMF using the Complaint Reporting System (CRS).

Definition:

For the purposes of the policy, a complaint is the expression of at least one of the following three elements:

• A reproach against AccèsConseil;
• The identification of real or potential harm that a consumer has sustained or may sustain; or
• A request for remedial action.

Informal steps to correct a specific problem are not considered a complaint, provided the problem is resolved as part of the registrant’s normal activities and the consumer has not filed a complaint.

Receipt of the complaint

To be admissible, a complaint must be made in writing by the complainant.

Consumers who wish to file a complaint must do so in writing at the following address:

AccèsConseil Mainguy Gagnon-Rochette inc.
Attn : Catherine Mainguy

2784, chemin Sainte-Foy

Québec, QC

G1V 1V8

Téléphone : (418) 687-4050

Télécopieur : (418) 687-1804

Employees who receive a complaint must immediately forward it to the person in charge of this policy.

The person in charge must acknowledge receipt of the complaint within a reasonable period of time, namely within 10 business days of receiving it.

The acknowledgment of receipt must contain the following information:

• A description of the complaint, specifying the real or potential harm, the reproach against AccèsConseil and the requested remedial action;
• The name and contact information of the person in charge of examining complaints;
• In the case of an incomplete complaint, a notice requesting more information to which the complainant must respond within a set deadline, failing which the complaint will be deemed to have been abandoned;
• The complaint examination policy;
• A notice stating that if not satisfied with the outcome or with the examination of the complaint, the complainant can request that the complaint file be transferred to the AMF. This notice must also mention that the AMF may offer dispute resolution services, if deemed appropriate;
• A reminder to the complainant that filing a complaint with the AMF does not interrupt the prescriptive period for civil remedies against the registrant.

Creation of complaint file

A separate file must be created for each complaint.

The file must contain the following:

• The written complaint and its three elements (the reproach against AccèsConseil, the real or potential harm and the requested remedial action);
• The outcome of the complaint examination process (the analysis and the supporting documents);
• The final written response to the complainant with justifying reasons.

Complaint examination

On receiving a complaint, AccèsConseil will initiate its complaint examination process.

The complaint will be examined within a reasonable period of time, namely within 90 days of receiving all the information necessary for the examination.

After examining the complaint, the person in charge must send the complainant a final response with justifying reasons.

Transfer of the file to the AMF

If not satisfied with the outcome or with the examination of the complaint, the complainant may ask AccèsConseil, at any time, to transfer the file to the AMF.

The transferred file must include all the information related to the complaint.

The registrant is responsible for complying with the rules governing the protection of personal information.

Creation and upkeep of a Register

A Register of complaints must be created for the purposes of the policy. Its upkeep will be the responsibility of the person in charge.

Any complaint corresponding to the definition of this expression shall be entered in the Register and, in particular:

• any written complaint, regardless of the level of intervention involved in handling the complaint;
• any legal proceeding within the meaning of the word "complaint";
• any complaint to the Chambre en Assurance de Dommage (CHAD) and the Chambre de la Sécurité Financière (CSF).

Biannual reports

Twice a year, the person in charge must use the CRS to file a report with the AMF detailing the number and type of complaints received. He must do so regardless of whether any complaints were received.

The reporting periods are as follows:

• no later than July 30, for data collected between January 1 and June 30;
• no later than January 30, for data collected between July 1 and December 31.

Penalty for non-compliance with policy
In the event of non-compliance with the policy, the employees are subject to disciplinary measures.