Complaints handling and dispute resolution policy

This policy falls within the framework of the legal provisions introduced by the Act respecting the distribution of financial products and services relating to the handling of complaints and the settlement of disputes.

Purpose of the policy

The purpose of this complaint handling and dispute settlement policy is to establish a fair and free procedure to deal with complaints received. It aims in particular to supervise the reception of complaints, the transmission of the acknowledgment of receipt and the notice to the complainant, the constitution of the complaint file and, where applicable, the transmission of the complaint file to the financial markets (hereinafter “the Autorité”) and the compilation of complaints with a view to the preparation and transmission of a biannual report to the Autorité.

The Complaints Officer

Mrs. Shawna Vincent, Operations Vice-President, is the person responsible for the application of this policy and ensures that complaints received by OVC Inc. are processed in accordance with this policy.

As an officer, Mrs. Vincent also acts as a respondent to the Autorité and sees to the training of staff and to provide them with all the information necessary to comply with this policy. Mrs. Vincent is also responsible for:

• Sending an acknowledgment of receipt and a notice to the complainant;

• Sending the file to the Autorité, at the complainant’s request;

• Maintaining a record of complaints;

• Submitting a report twice a year to the Autorité, through the Complaint Reporting System (PRS).

Definition of a complaint

For the purposes of this Policy, a complaint must be in writing and include at least one of the following three elements that remains after being considered and dealt with at the operational level competent to render a decision.

• A reproach against the company;

• Identification of any harm suffered or that could be suffered by the complainant;

• A request for corrective action.

Informal action to correct a particular problem or to obtain information, if the problem is dealt with during our firm's regular activities, does not constitute a complaint.

First, either before filing a complaint in writing, the complainant is encouraged to communicate with his representative or with customer service, by phone 514-600-2739 or directly with the Service Director, Mr. Francis Leclaire, by email to the following address: Mr. Leclaire is responsible for handling operational dissatisfaction.

If the consumer remains dissatisfied and their dissatisfaction must be addressed by Mrs. Vincent, then this is a complaint.

How to file a complaint?

The complainant who is not satisfied with the answers or information obtained from Mr. Francis Leclaire and who wishes to lodge a complaint must do so in writing to the following address, mentioning as subject: "Complaint - to be given to Mrs. Shawna Vincent":

OVC Inc.

202-320, Murano, Sainte-Julie, QC, J3E 0C6

Tel.: 514-313-5999

Fax: 855-630-3781

The file must include the following elements:

The identification of a potential or real harm that a consumer has suffered or could suffer and the details of the alleged facts, dates, and other information necessary to analyze the case. For a reproach against an employee, the request must include the name of the person concerned. The complainant must provide his full contact details:

• Name

• Address

• Telephone number

• Email address

• Insurance policy number

Receipt of the complaint

Any broker or firm employee who receives a written complaint must refer it, upon receipt, to Mrs. Vincent. Upon receipt of a written complaint, Mrs. Vincent will send a written acknowledgment to the complainant within a reasonable time, i.e. within 5 business days.

The acknowledgment of receipt of the complaint will contain the following information:

• A copy of this policy;

• A description of the complaint received specifying the reproach made against the firm and/or its employee and the request for corrective action;

• The name and contact details of the Officer responsible for processing the complaint;

• In the event of an incomplete complaint, a notice stating the need to send the Officer additional information within 10 working days, failing which the complaint is deemed to have been abandoned;

• Notice to the complainant.

Processing of a complaint

Upon receipt of a written complaint, Mrs. Vincent initiates the processing process and entrusts the file for investigation. The complaint must be processed within 20 business days after receipt of all the information necessary for its analysis. Following examination of the complaint, a final written and reasoned response is sent to the complainant.

Constitution of the complaint file

Each complaint must be the subject of a separate file. This file must include the following elements:

• The complainant's written complaint, including the elements of the complaint (the complaint against the firm or the representative; the actual or potential harm; the corrective action requested);

• The outcome of the complaint handling process (analysis and supporting documents);

• The final response to the complainant, written and reasoned.

Transmission of the file to the Autorité

If the complainant is not satisfied with the final position obtained or the handling of his complaint, he can ask us, at any time, to transfer his complaint file to the Autorité des marchés financiers (AMF). The transferred file consists of all the information relating to the complaint. Respecting the rules for the protection of personal information in our possession remains our responsibility.

Creation and maintenance of a record

The firm establishes a record of complaints for the purposes of applying this policy. Its updating is Mrs. Shawna Vincent’s responsibility.

Report to the Autorité

Twice a year, Mrs. Vincent sends the AMF, whether she has received complaints or not, a report outlining the number and nature of complaints received. The reporting periods are as follows:

• No later than July 30th, for complaints received between January 1st and June 30th;

• No later than January 30th, for complaints received between July 1st and December 31st.

Coming into effect

This policy came into effect on January 12th, 2017, it was revised on July 1st, 2018 and September 9th, 2020.