Dispute and Complaint Handling Policy

Purpose of the Policy

The purpose of this dispute and complaint handling policy is to establish a free, simple, and fair procedure for handling them.

It aims to identify the person responsible for handling complaints, to oversee the receipt and processing of complaints, and, where applicable, the transfer of the file to the Autorité des marchés financiers, hereinafter referred to as the “Authority”.

Responsible Person

The person responsible for applying this policy within Cabinet ADQ Inc. is Mohamed Harb, the president.

Under this policy, their duties include, among others:

• To send an acknowledgment of receipt to the complainant within 10 business days of receiving a complaint.
• To analyze disputes and complaints within a reasonable timeframe (note that the responsible person may delegate this task while ensuring its supervision).
• To decide on the outcome of the analysis and inform the complainant.
• To transfer the file to the Authority, at the complainant’s request.
• To maintain a register of complaints.
• To report complaints twice a year* to the Authority, through the system provided for this purpose. (*Note: A later section specifies annual reporting. See “Complaint Reporting Procedures” below.)

Receipt of the Complaint

A consumer or client of Cabinet ADQ Inc. who wishes to file a complaint may do so, verbally or in writing, by contacting the responsible person:

• Mail: 1955 ch. De La Côte-de-Liesse, suite 201, Saint-Laurent, QC H4N 3A8
• Phone: 514-640-5172 ext 327
• Email: Mohamed.Harb@assuruni.com

Handling of a Complaint

For the purposes of this policy, a complaint constitutes the verbal or written expression of at least one of the following elements, which persists after1 having been considered and handled at the competent operational level for decision-making.

It must contain one of the following elements:

• Identification of potential or actual harm that a consumer has suffered or could suffer, and the details of the alleged facts, dates, and other information necessary to analyze the file.
• A reproach against the firm, a representative, or an employee.
• The request for a corrective measure.

An initial expression of dissatisfaction from the consumer, whether written or not, does not constitute a complaint when this dissatisfaction is resolved in the normal course of the registrant’s activities. However, as a guideline, if the consumer remains dissatisfied and their dissatisfaction must be handled by the person responsible for complaint processing, then it is considered a complaint.

The complainant must provide their full contact information, including:

• First and last name of the complainant
• Address
• Phone number
• Email address

Upon receipt of a complaint, the person responsible for handling complaints will send an acknowledgment of receipt to the complainant within3 10 business days of receiving the complaint.4 They will conduct an impartial analysis within a reasonable timeframe, which should not exceed 60 business days*, following receipt of the complaint and the elements necessary for its analysis.

In the case of an incomplete complaint, a5 notice requesting additional information will be sent to the complainant. The complainant must provide the necessary information before the analysis of the file can resume or continue.6

The complaint must be handled impartially and within a reasonable timeframe, which should not exceed 60 days* following receipt of the complaint. This timeframe should be respected, regardless of the different levels of processing involved.

(*Note the difference: the first instance specifies “business days,” the second just “days.”)

Complaint Register and File

The firm must maintain a register of the complaints it receives. Each complaint must have a separate file containing the following elements:

• A description of the complaint received.
• The outcome of the complaint handling process (the analysis and supporting documents).
• All information related to the complaint.
• The final response to the complainant, written and reasoned.

Transmission to the Authority

If the complainant is not satisfied with the outcome of their complaint’s handling or with the handling itself, they may ask the responsible person to transfer their complaint file to the Authority.

Address to use for the transfer:

AUTORITÉ DES MARCHÉS FINANCIERS

Place de la Cité, Cominar Tower

2640 Laurier Boulevard, Suite 400

Quebec City, Quebec G1V 5C1

The file transferred to the Authority will consist of all documents related to the complaint.

The transfer must be made to the Authority within 30 days of the complainant’s request.7

Complaint Reporting Procedures

The firm must annually report to the Authority the complaints received from a consumer or client during the reporting period, namely from January 1st to December 31st.

A firm that has received no complaints during the period must report that it received none.

Since November 7, 2022, the complaint entry and reporting process has been standardized for the entire industry and is accessible via the Authority’s online services (SEL) (for businesses) in the section called “Complaint Report”.

The complaint reporting period is from March 1st to May 1st of each year, to report complaints received between January 1st and December 31st of the previous year.

Policy Effective Date: 2023-09-20