1) Purpose of the Policy

The intent of this policy is to establish and maintain a fair procedure for the review and handling of complaints free of charge. It also aims to provide oversight of the complaint review process so that each one is dealt with in a timely manner and resolved effectively.

2) Complaints Officer

The Complaints Officer is Mrs Mylène Tessier, having his principal place of business at 3200 A. Jean-Noël-Lavoie, Laval, QC H7T 2H6  and can be reached by email at francois@excelia.ca or by telephone at 514-370-0500. All complaints are forwarded to Mrs. Tessier. All complaints submitted by a client must be reported immediately to the Complaints Officer, who is responsible for solving them and reporting them to l’Autorité des marches financiers (AMF), if necessary.    

The Complaints Officer ensures that the policy in effect is followed by Excelia Group, its employees and representatives, and that adequate training is offered periodically on the subject.

3) What Constitutes a Complaint?

A complaint constitutes the expression of one of the three following factors, and remains after having been considered and processed at the operational level competent to render a verdict:

•  reproach against the company or one of its representatives
• The reporting of potential or real damages that a client has suffered or could suffer
• A request for corrective action

As such, it is not considered a complaint when a client first expresses dissatisfaction, whether in written form or not, and it is settled in the normal course of the business activities. However, if the client remains dissatisfied and their dissatisfaction requires the attention of the Complaints Officer, then it constitutes a complaint.

4) Complaints Log

To record a complaint in writing, Excelia Group must register it in the Complaints Log created for this purpose. If a client makes a verbal complaint, the Complaints Officer must then document it in writing in the Complaints Log. The Complaints Log must specifically contain the following information:

• Excelia Group complaint reference number
• Identification of the complainant
• Brief description of the statements contained in the complaint, including alleged damages and the corrective action requested
• Date the complaint was recorded in the log
• Date the acknowledgement of receipt is sent to the client
• Date the final position is sent to the client
• The outcome of the complaint treatment process
• Date the file is forwarded to l’Autorité des marches financiers (AMF), if applicable
• Date the file is closed

5) Complaints Treatment Process

Within 10 days of recording a complaint in the complaints log, Excelia Group must provide the client with an acknowledgement of receipt containing, at minimum, the following:

• A description of the complaint detailing the real or potential damages suffered, the alleged facts and the corrective action requested
• The name and contact details of the person responsible for examining the complaints
• In the case of an incomplete complaint, a notice is sent to the client requesting further information be sent within a fixed deadline
• The review process, including the complaint processing time the client can expect
• A notice indicating that if the client in dissatisfied with the result or the review process, they can request that the complaint file be forwarded to l’Autorité des marches financiers (AMF)
• A reminder to the client that the transfer of a complaint to the AMF will not interfere with the limitation period for civil actions.

In the case of a complaints file transfer, the representative must make sure to respect rules concerning the protection of personal data. A representative or employee is prohibited from concluding an amicable settlement with the client, paying them compensation, or making restitution. A file must be created for each complaint and include all relevant information, such as:

• The complaint and all documents submitted by the client
• All information relevant to the complaint and its handling, including supporting documents for analysis
• The outcome of the treatment process and the final response and justification, documented in writing

The Complaints Officer must examine and document each complaint received by Excelia Group and make a recommendation to the Chief Executive Officer, Mr. Hugo Neveu. Once accepted, the Complaints Officer must present the outcome in a letter including a description of the complaint, the results of the internal review, and the justification of Excelia Groupe’s final decision as well as the process for bringing the complaint to l’Autorité des marches financiers (AMF) if the client is dissatisfied with the handling of their complaint.

Customer Acceptance of the Proposed Solution

When the client and Excelia Group, as mediated by the Complaints Officer, come to a settlement, the client must sign a release in favour of Excelia Group.

Client Refusal of Proposed Solution

If the client is dissatisfied with the results of the internal review by Excelia Group, they can request that a copy of their file and the written complaint be forwarded to l’Autorité des marchés financiers (AMF).

6) Reporting to l’Autorité des marchés financiers

According to the applicable regulations, the Complaints Officer must report client complaints received by Excelia Group twice a year. Reporting periods are from January 1 to June 30 and from July 1 to December 31 of each year. Reports much be submitted through the Complaints Reporting System (SRP) at the latest by July 30 and January 30, respectively. If the firm has only one representative subject to the Act Respecting the Distribution of Financial Products and Services, the AMF does not require the production of a report in the absence of a complaint. However, when a complaint is received, the firm is obliged to report it according to established procedures.

7) Other Provisions

The Complaints Policy must be reviewed annually by the Complaints Officer who documents all policy reviews specifically including content needing to be modified with justifications, if applicable. If an external audit is performed, the report’s recommendations must be incorporated into the policy, if applicable. This Compliance Policy is effective as of February 1, 2022.