Any complaint submitted to an Advisor or directly to the Company will be taken in earnest and will be dealt with in a professional manner that maintains respect for the client. Advisors are not permitted to make settlements directly to clients. All settlements must be done through the Company with appropriate documentation.  

Definitions

 A “complaint” is any written statement of a client, or any person acting on behalf of a client, alleging a grievance involving the conduct, business, or affairs of the Company or any Advisor of the Company including a grievance against an Advisor, or claim of potential or experienced harm due to an Advisor or staff member of the Company.

There may be instances where the Company or its Advisors receive a verbal complaint from a client which will warrant the same treatment as a written complaint. Such situations depend upon the nature and severity of the client’s allegations and require the professional judgment of the Compliance Officer handling the complaint.

If a client expresses a verbal concern to the Company or his/her Advisor that cannot be easily solved to the satisfaction of the client by the Advisor, then the Company requests that the client submits his/her complaint in writing to the Advisor who will pass the complaint on to the Compliance Officer. Alternatively the client may directly submit the complaint to the Compliance Officer.

Reporting A Complaint

 All complaints and pending legal actions must be disclosed by Advisors to the Company’s Compliance Officer or Management in writing within 2 business days. Failure to do so will be considered to be a serious breach of the Company’s policy which may result in disciplinary action and may even be grounds for dismissal with cause. We advise all Advisors to immediately take the time to fully document all conversations, meetings, dates, times, etc. relating to a “problem” whenever they receive a complaint or anticipate one.

Complaint Procedure

 All Advisors are requested to have a Client Complaint File even if the Advisor has never received a complaint and the file is therefore empty. The Company will handle client complaints in the following manner:

1. A client who files a complaint against an Advisor will receive a letter of acknowledgement;
   
   
2. A Complaint Report will be completed. The report includes the following:
   • the name of the individual at head office handling the complaint;
   • the date of the complaint;
   • the complainant’s name, address, telephone and facsimile numbers as well as email address, if applicable;
   • the name of the person who is the subject of the complaint;
   • the investment(s) or service(s) which is/are the subject of the complaint; and
   • the date and conclusions of the decision rendered in connection with the complaint.
   
   
3. If an Account Representative receives the complaint he/she will complete and file the complaint report in the client’s system journal and forward the complaint to the Compliance Officer where the complaint will be filed in the Company complaint log and be handled by the Compliance Officer;
   
   
4. If the Company receives the complaint, the Compliance Officer will complete and file the complaint report in the head office complaint log, and will forward a copy of the complaint to the applicable Advisor who will file the complaint in his/her complaint log.
   
   
5. The Compliance Officer will send acknowledgement of receipt of the complaint to the client, of the client’s legal counsel, within 5 business days of receipt of the complaint. This acknowledgment will include:
   • a copy of the Client Complaint Information document as a stand-alone document;
   • the name and contact information of the Compliance Officer responsible for handling the complaint; and
   • disclosure that depending on the nature and complexity of the complaint, the duration between acknowledgement of the complaint and mailing of the written summary of investigation to the client should be approximately 4-6 weeks.
   
   
6. The Compliance Officer will ensure that Advisors are made aware of all complaints filed by their clients;
   
   
7. The complaint will be reported to the CCO and appropriate regulators whenever a written client complaint is received or when the complaint involves allegations of theft, misappropriation of funds or securities, or of forgery;
   
   
8. Within the next 4-6 weeks, the Compliance Officer will investigate and analyze the matters specific to the complaint and in a timely manner advise both the Advisor and branch manager of any additional procedures or information required of them;
   
   
9. Upon completion of the investigation:
   • a written summary which addresses the clients concerns will be prepared;
   • the Advisor will be provided the opportunity to review the response and provide comments for a limited time period;
   • the Compliance Officer will give due consideration to comments received from the Advisor within the allotted time period and may or may not revise the letter;
   • the letter will be forwarded to the client
   (Note: There is no requirement that the Advisor agree with the Company’s findings or resolution of the complaint)



10. In the event it is not possible to complete the investigation and provide a response to the client within 6 weeks, a further communication will be sent to the client at least three days prior to the 6 week period lapsing to inform the client when a summary and response to the investigation can be expected.