1. Purpose of the policy

The purpose of this policy is to institute a procedure for the equitable processing, at no charge, of all complaints received by Assurance C. Pilon / Assurance M. Pilon , hereinafter referred to as "the firm". It is intended in particular to provide a framework for the receipt of complaints, the sending of acknowledgements and notices to the complainant, the establishment of complaint files, the transfer of the complaint file to the Autorité des marchés financiers (hereinafter referred to as "the Autorité") if applicable, and the compilation of complaints with a view to the preparation and submission of an annual report to the Autorité.

2. Interpretation and application

2.1 Christiane Pilon, Claims manager, shall be responsible for the application of this policy, its administration and all other procedures and forms related to this policy

2.2 As the person responsible for the application of this policy, the person identified in subsection 2.1 shall act as the respondent with respect to the Autorité and shall ensure that all personnel receive the training and the relevant information required for compliance with this policy.

2.3 In addition to the responsibilities mentioned previously, the person responsible has the following duties :

1. to acknowledge receipt of complaints in accordance with subsection 4.3;
2. to send the necessary notices: see clause 4.3 e) in this regard;
3. to forward the file to the Autorité, at the complainant's request: see section 7 in this regard;
4. to maintain a complaints register: see section 8;
5. to forward a copy of all complaints to the person responsible for the policy, describing the nature of the complaint together with the reply to the complainant.

3. Complaint

3.1 To be admissible, a complaint must be made in writing by the complainant. Legal proceedings instituted by the complainant are included under the category of complaints made in writing.

3.2 For the purposes of this policy, the written complaint must include the following three elements :

1. a reproach made with regard to the firm, one of its brokers, or one of its employees;
2. the identification of a real or potential harm that a consumer has suffered or could suffer;
3. a claim for remedial action.

3.3 The following does not constitute a complaint: any first-level intervention consisting of a communication from the consumer that is a matter of informal approach intended to correct a specific problem, as long as the problem is handled in the context of regular activities and the consumer does not need to file a formal complaint.

3.4 If the complaint corresponds to the definition of a "claim" under the professional liability insurance policy of the firm, the following procedure must be followed:

1. the firm forwards to the insurer the written complaint received from the complainant, requesting that the insurer confirm that he will communicate with the client to process this complaint; the claims manager working at Assurance C. Pilon/Assurance M. Pilon has the responsibility to forward the complaint to the firm's professional liability Insurer;
2. this notice to the professional liability insurer must also specify that if the insurer does not contact the firm within 10 working days to confirm that he will process the complaint, the firm will assume responsibility for the processing of this complaint.

4. Receipt of the complaint

4.1 A consumer who wishes to file a complaint must send it in writing to the following address:

Par courrier: Assurance C. Pilon / Assurance M. Pilon / Flex Assurance Inc., 999 rue Dollard, Local #23, Gatineau, Qc. J8L 3E6

Phone: 819-281-6464 poste 6 ou 1 866-951-6464

Email: christiane@assurancempilon.com

4.2 Any broker or employee of the firm who receives a complaint must immediately refer it to the person responsible (see subsection 2.1) for the application of this policy.

4.3 The person responsible shall acknowledge receipt of the complaint within 5 working days.

The notice of receipt must contain the following information (the model provided in appendix 1 may be used) :

1. A copy of this policy;
2. A description of the complaint received, specifying the issue invoked with regard to the firm, its broker or its employee, and the request for remedial action;
3. The name and contact information of the person in authority responsible for the processing of the complaint;
4. In the case of an incomplete complaint, a notice mentioning the need to provide additional information to the person responsible within 5 working days, failing which the complaint is considered to have been cancelled.
5. Information for the complainant concerning his right, upon the expiration of the 15-day period following the receipt of all necessary information and not later than one year following the response to his complaint, to request that his file be forwarded to the Autorité if he is not satisfied with the response or the processing of his complaint. The notice must also mention that the Autorité may offer mediation if the parties consent to it;
6. Information for the complainant to the effect that mediation is a process of out-of-court settlement of a conflict whereby a third person (the mediator) intervenes with the parties to help them reach satisfactory agreements;
7. A reminder to the complainant that the filing of a complaint with the Autorité does not interrupt the prescription with respect to actions in the civil courts against the firm.

5. Establishment of the complaint file

5.1 A separate file must be opened for each complaint received.

5.2 The file must include the following elements :

1. the complainant's written complaint, including the three elements of the complaint (the reproach with regard to the firm or the broker or the employee, the real or potential harm and the remedial action requested);
2. the outcome of the complaint-processing process (the analysis of the supporting documents);
3. a copy of the final justified response transmitted by the firm to the complainant.

6. Processing of a complaint

6.1 Upon receipt of a complaint, the person responsible (2.1) shall conduct an investigation.

6.2 The complaint must be processed within 15 working days following the receipt of all the necessary information.

6.3 When the investigation is completed, the person responsible shall transmit the firm's final justified response to the complainant.

7. Transfer of the file to the autorité

7.1 When the complainant is not satisfied with the firm's examination of his complaint or with its outcome, he may ask the firm to forward his complaint file to the Autorité.

7.2 This right may only be exercised by the complainant upon the expiration of the period of 15 working days specified for the provision of a final response, or at the latest 1 year after the final response has been obtained.

7.3 The file transferred to the Autorité contains all the material related to the complaint file.

8. Creation and updating of a register

8.1 The firm shall establish a complaints register for the purposes of the application of this policy. The register shall be updated by the person responsible for the application of this policy (section 2).

8.2 All written complaints corresponding to the definition in section 3 must be entered in this register. More precisely, a complaint must be entered in the register regardless of the degree of intervention required for its processing.

9. Report

At the latest on July 30th for complaints received between January 1st and June 30th and at the latest on January 30th for complaints received between July 1st and December 31st, the person responsible shall submit to the Autorité a report on the number and nature of complaints received according to the categories defined in the register.

10. Notice to brokers and other employees of the firm

The person designated as responsible under subsection 2.1 shall ensure that the brokers and other employees of the firm are informed of the policy on the processing of complaints and resolution of disputes and that they have a copy of it.

11. Effective date

This policy took effect on may 17, 2016, was revised on november 1, 2021