COMPLAINTS PROCESSING AND DISPUTE RESOLUTION POLICY
The purpose of this policy is to ensure the fair handling of complaints and disputes received from our clients.
This policy is intended to provide a framework for:
This policy is intended to provide a framework for:
- Establishing a free, accessible, and easy-to-use complaint handling service for our clients;
- Providing clients with information to help them understand how we process their complaints;
- Managing complaints from receipt through to resolution.
WHAT WE CONSIDER A COMPLAINT
A complaint is an expression of dissatisfaction or a reproach from a client regarding the services or products we offer, together with an expectation that we will take action to address the issue. For example, a client may expect compensation, an apology, or corrective measures to remedy or stop the situation that gave rise to the complaint.
Certain communications are not considered complaints
The following examples are not complaints:
However, we consider a request to correct an administrative error to be a complaint when that error results in additional consequences for the client or for several clients. For example, this would be the case if the error resulted in fees that must be reimbursed to the client(s).
Certain communications are not considered complaints
The following examples are not complaints:
- A request for information or documentation regarding a product or service offered;
- A claim for compensation or an insurance claim;
- A request to correct an administrative error, such as a transcription error or an error in the calculation of an amount due;
- A request to access or amend personal information;
- A comment or observation about our organization.
However, we consider a request to correct an administrative error to be a complaint when that error results in additional consequences for the client or for several clients. For example, this would be the case if the error resulted in fees that must be reimbursed to the client(s).
PERSON RESPONSIBLE
The person responsible for the application of this policy is Noel El Feghali, Président.
Our Complaints Officer ensures the fair treatment of complaints received and oversees compliance with and implementation of this policy within the firm, including ensuring that:
Our Complaints Officer ensures the fair treatment of complaints received and oversees compliance with and implementation of this policy within the firm, including ensuring that:
- Management and staff are aware of and apply this complaint handling policy;
- Clients can easily obtain information regarding how complaints are handled or about the status of their complaint;
- Staff carry out the follow-up required for the proper handling of client complaints;
- The person assigned to handle a complaint possesses the skills and knowledge required to do so;
- Each complaint is handled objectively and with due consideration for the client's interests.
COMPLAINT HANDLING PROCESS
We handle each complaint objectively while considering the interests of the client who submitted it, and we communicate with clients in clear and simple language.
Clients may contact us at any time to obtain information about our complaint handling process, to submit a complaint, or to inquire about the status of a complaint.
You may submit your complaint using the method most convenient for you. You may also complete the complaint form available on the website of the Autorité des marchés financiers (AMF). We can assist you in formulating your complaint.
Contact Information
To contact us or to obtain information regarding our complaint handling process:
When a client expresses dissatisfaction or a reproach, we determine whether the communication constitutes a complaint. We consider all information provided by the client in making this assessment. If there is uncertainty, we will contact the client to better understand the situation and determine whether a complaint is being made.
We are responsible for helping clients clearly formulate their complaints, including by asking questions to better understand the situation. We also ensure we understand the client's expectations, such as whether they are seeking a correction, reimbursement, apology, or other remedy.
Complaint intake
Each complaint is recorded in our complaint register upon receipt.
We ensure that complaints are acknowledged promptly and handled as quickly as possible.
Acknowledgement of reception
We acknowledge receipt of the complaint in writing within 10 days and inform the client of their right to have their complaint file examined by the AMF.
We also provide information regarding the expected timeframe for our response and how to obtain updates regarding the handling of the complaint.
Documentation of complaints
A file is created for each complaint. We ensure that the complaint file remains current and contains all relevant documents and information collected throughout the complaint handling process.
Complaint files are retained for the same period as client files and in accordance with our Privacy Policy.
Clients may contact us at any time to obtain information about our complaint handling process, to submit a complaint, or to inquire about the status of a complaint.
You may submit your complaint using the method most convenient for you. You may also complete the complaint form available on the website of the Autorité des marchés financiers (AMF). We can assist you in formulating your complaint.
Contact Information
To contact us or to obtain information regarding our complaint handling process:
- By mail : 201-1955 Chemin de la Côte-de-Liesse, Montréal, Quebec H4N 3A8
- By telephone : 514-447-7987 ext. 733
- By email: plaintes.complaints@panda7.ca
When a client expresses dissatisfaction or a reproach, we determine whether the communication constitutes a complaint. We consider all information provided by the client in making this assessment. If there is uncertainty, we will contact the client to better understand the situation and determine whether a complaint is being made.
We are responsible for helping clients clearly formulate their complaints, including by asking questions to better understand the situation. We also ensure we understand the client's expectations, such as whether they are seeking a correction, reimbursement, apology, or other remedy.
Complaint intake
Each complaint is recorded in our complaint register upon receipt.
We ensure that complaints are acknowledged promptly and handled as quickly as possible.
Acknowledgement of reception
We acknowledge receipt of the complaint in writing within 10 days and inform the client of their right to have their complaint file examined by the AMF.
We also provide information regarding the expected timeframe for our response and how to obtain updates regarding the handling of the complaint.
Documentation of complaints
A file is created for each complaint. We ensure that the complaint file remains current and contains all relevant documents and information collected throughout the complaint handling process.
Complaint files are retained for the same period as client files and in accordance with our Privacy Policy.
COMPLAINT ANALYSIS
Understanding the complaint and the client's expectations
The person responsible for analyzing the complaint must obtain all information necessary to assess it. This may include contacting the client for additional information or requesting documents and information from staff members or representatives involved.
Final written response
We provide a final written response within 60 days.
We may provide one of the following responses:
The issuance of our response does not end communications with the client. We continue to respond to inquiries, comments, and any new relevant information related to the complaint.
Extension of the response period
In some cases, the person handling the complaint may determine that additional time is required due to the complexity of the matter. Any extension may not exceed 30 additional days.
Examples of circumstances that may justify an extension include:
Evaluation of settlement offers
When we propose a resolution, we provide the client with a reasonable amount of time to evaluate the offer. The timeframe will reflect the complexity of the matter and allow the client to seek advice before accepting, rejecting, or making a counteroffer.
Once an agreement is reached, we have 30 days to implement it unless another timeframe is agreed upon and is in the client's interest.
We never require a complainant to withdraw another complaint as a condition of settlement. Furthermore, settlement conditions will never prevent a client from:
The person responsible for analyzing the complaint must obtain all information necessary to assess it. This may include contacting the client for additional information or requesting documents and information from staff members or representatives involved.
Final written response
We provide a final written response within 60 days.
We may provide one of the following responses:
- We agree to the client's request and propose corrective action, reimbursement, an apology, or another appropriate remedy;
- We propose a solution that partially satisfies the client's request or differs from the requested remedy, with the goal of reaching a mutually acceptable resolution;
- We reject the complaint if, following our analysis, we determine that it is unfounded or that no resolution is possible.
The issuance of our response does not end communications with the client. We continue to respond to inquiries, comments, and any new relevant information related to the complaint.
Extension of the response period
In some cases, the person handling the complaint may determine that additional time is required due to the complexity of the matter. Any extension may not exceed 30 additional days.
Examples of circumstances that may justify an extension include:
- Delays caused by factors beyond our control, such as waiting for documents from a third party;
- Exceptional circumstances, such as a significant increase in complaint volume following a natural disaster.
Evaluation of settlement offers
When we propose a resolution, we provide the client with a reasonable amount of time to evaluate the offer. The timeframe will reflect the complexity of the matter and allow the client to seek advice before accepting, rejecting, or making a counteroffer.
Once an agreement is reached, we have 30 days to implement it unless another timeframe is agreed upon and is in the client's interest.
We never require a complainant to withdraw another complaint as a condition of settlement. Furthermore, settlement conditions will never prevent a client from:
- Requesting a review of their complaint by the AMF;
- Contacting the AMF, the Chambre de la sécurité financière, the Chambre de l'assurance de dommages, or the Canadian Investment Regulatory Organization (CIRO).
REVIEW OF A COMPLAINT FILE BY THE AMF
Clients have the right to request that their complaint be reviewed by the AMF if they are dissatisfied with the way we handled their complaint or with our response.
Clients may request that we transfer their complaint file to the AMF or may contact the AMF directly. In either case, we will transmit the complaint file within 15 days of receiving the request.
SIMPLIFIED PROCESS FOR CERTAIN COMPLAINTS
Certain complaints may be handled through a simplified process where we are able to provide a satisfactory resolution within 20 days.
A complaint is considered resolved to the client's satisfaction when the client accepts the proposed solution or when the explanations provided satisfactorily address the concern.
Under this process: complaints may be handled by a member of our customer service team. A written acknowledgement of receipt and a formal written final response are not required. Communications may be conducted verbally, such as by telephone.
For each complaint handled under this process, the individual responsible must:
If we determine that the complaint cannot be resolved to the client's satisfaction within 20 days, we will notify the client in writing before the end of that period and continue the complaint under the standard complaint handling process.
A complaint is considered resolved to the client's satisfaction when the client accepts the proposed solution or when the explanations provided satisfactorily address the concern.
Under this process: complaints may be handled by a member of our customer service team. A written acknowledgement of receipt and a formal written final response are not required. Communications may be conducted verbally, such as by telephone.
For each complaint handled under this process, the individual responsible must:
- Inform the client of the receipt of the complaint and the client's right to request a transfer of the complaint file to the AMF (within 10 days);
- Provide the client with our response and proposed resolution (within 20 days).
If we determine that the complaint cannot be resolved to the client's satisfaction within 20 days, we will notify the client in writing before the end of that period and continue the complaint under the standard complaint handling process.
OUR RESPONSIBILITIES
Representatives and employees
Any representative or employee who receives a complaint must promptly forward it to the individuals responsible for complaint handling.
They must cooperate fully in the handling of the complaint and provide any documents or information necessary for its review.
Staff assigned to complaint handling
The individual responsible for handling a complaint must not do so if they are unable to remain objective.
They must ensure they possess the necessary knowledge and competencies to handle the complaint and seek assistance where appropriate.
They are responsible for gathering information and documents necessary for the analysis of the complaint and may contact the client to obtain clarification regarding the circumstances giving rise to the complaint or the client's expectations.
Management responsibilities
We ensure that this policy is communicated to all staff and that everyone understands their responsibilities.
For example, all personnel who may be involved in handling complaints receive a copy of our complaint handling policy and procedures upon joining the organization and are informed of any subsequent changes.
We establish the procedures and processes necessary to handle complaints effectively and ensure that staff involved in complaint handling receive appropriate training.
We appoint a Complaints Officer only after confirming that the individual possesses the competencies required to fulfill the role.
We also ensure that management and staff cooperate fully in the handling of complaints.
