Complaints Management Policy

This policy aims to establish a clear, free, simple, and fair framework for the handling, processing, and follow-up of complaints and incidents received within the firm. It aims to ensure uniform, rigorous, and compliant treatment in accordance with regulatory requirements in effect as of July 1, 2025.

The persons responsible for implementing this policy within the firm are Maude Soucy and Roxanne Duval. Our officers also ensure that staff are trained and informed to ensure compliance with this policy.

Contact details of the complaints officers:

"Any verbal or written expression of a reproach or dissatisfaction concerning a product or service offered by the firm, made by a client, for which the client expects a final response including, where applicable, the implementation of corrective measures."

Not considered complaints: simple requests for information, clarifications, or minor dissatisfactions resolved in the initial exchange without expectation of formal follow-up. [1] Autorité des marchés financiers. Complaints Handling.

Step 1: Receipt

Complaints may be received:

• verbally;
• in writing;
• by email;
• via our website

Any broker may receive a complaint but must immediately inform the person responsible mentioned above.

Step 2: Sending an Acknowledgment of Receipt

• The complaints officer sends a written notice to the client within 5 business days
• The client is informed of their right to contact the Autorité (AMF)

Step 3: Analysis

• Review of facts, documents, communications, and impacts
• Consultation with employees concerned
• Determination of the cause

Step 4: Processing and Decision

• Propose and apply, if necessary, corrective measures.
• Draft a clear, motivated, and documented final response.
• Send the response to the client

Step 5: Closing the File

• Archiving the file.
• Identification of trends or recurring causes.

The firm undertakes to process all complaints within a harmonized maximum period of 60 days, including analysis, measures taken, and final response. It is important to note that the 60-day period begins when all documents required for processing the complaint are received by our firm.

If the client remains dissatisfied with the final response received following the processing of their complaint, the complainant may request the transfer of their file to the AMF. The Officer then transmits:

• the entire complaint file;
• the final response provided;
• all relevant supporting documents.

It is recommended to use the AMF's MODEL complaint form so that the person can complete the complaint properly.

DOWNLOAD THE AMF MODEL FORM (OFFICIAL A)

This policy is subject to change according to AMF directives. This policy is currently in effect and was last modified in January 2026.