Summary of the dispute and complaint handling policy

Policy goal

The goal of this policy is to put in place a cost-free dispute and complaint handling procedure that is both simple and fair.

This policy seeks in particular to identify the person in charge of handling disputes and complaints, to determine how complaints are received and handled and, as applicable, how complaints are forwarded to Québec’s Autorité des marchés financiers (AMF).

Person in charge

The person in charge of applying this policy within Courtage Innovation Inc. (operating under the trademark of Demano) is Éric Manseau, company director.

In connection with this policy, the abovementioned person is responsible for carrying out various tasks, including the following:
• Sending an acknowledgment to the complainant within 10 business days of receipt of his/her complaint.
• Reviewing disputes and complaints within a reasonable timeframe (please note that the person in charge may delegate this task, provided that he or she supervises the process).
• Come to a decision on the review outcome and inform the complainant thereof.
• Forward the complaint to the AMF, if the complainant so desires.
• Report complaints to the AMF twice a year, using the system provided for that purpose.

Submitting complaints

Consumers or Demano clients who wish to submit complaints may do so verbally or in writing by contacting the person in charge via:
• Regular mail: 365 Rue Saint-Jean, Suite 207A, Longueuil, Québec J4H 2X7
• Telephone: (450) 674-6258
• Email: emanseau@rccaq.com

Handling complaints

For the purposes of this policy, a complaint is defined as the verbal or written expression of at least one of the following elements, which remains unresolved after having been considered and handled at the appropriate operational level for decision-making purposes.

Complaints must contain at least one of the following elements:
• The identification of potential or actual damages that a consumer may have already suffered or may suffer in the future, together with details of the alleged facts, dates and other information necessary for file review purposes.
• An accusation made against a firm, a representative or an employee.
• A request for corrective action.

Once a complaint has been received, the person in charge of handling complaints must send an acknowledgement of receipt to the complainant within 10 business days. An impartial review must be carried out within a reasonable timeframe (no longer than 60 business days) following receipt of the complaint and of the information required for analysis purposes.

If the complaint is incomplete, a notice including a request for information must be sent to the complainant, who must provide the missing information before the complaint can be properly reviewed. The complaint must be handled impartially and within a reasonable timeframe, i.e. no more than 60 business days following receipt of the complaint. This deadline must be complied with regardless of how many levels of intervention are required.

Forwarding complaints to the AMF

If complainants are dissatisfied with the complaint review outcome or with the handling process itself, they may ask the person in charge to forward their file to the AMF.

Address for forwarding complaints
AUTORITÉ DES MARCHÉS FINANCIERS
Place de la Cité, Cominar Tower, 2640 Laurier Blvd., Suite 400
Québec City, Québec G1V 5C1
Files forwarded to the AMF must include all documents/information relating to the complaint.

Complaint files must be forwarded to the AMF within 30 days of the complainant’s request.

The complete version of the policy will be sent on request to the person responsible for its application.

Effective date of the policy: August 1, 2022