Complaint Handling Procedures

Objective of the Policy

This policy aims to govern the management of complaints and the resolution of disputes. It pertains to the receipt and handling of complaints for Alpha Distinction Inc. (hereinafter referred to as “Alpha Distinction”), as well as the transmission of these complaints and the preparation of reports for the Autorité des Marchés Financiers (hereinafter “AMF”).

Implementation of the Policy

Alpha Distinction is responsible for the implementation of this policy. Alpha Distinction is the primary contact for the AMF and ensures, if necessary, that its staff are trained in complaint handling and dispute resolution. It also ensures that this policy is communicated to the staff and that the necessary tools for its implementation are provided. Additionally, Alpha Distinction is committed to fulfilling all its obligations.

Definition of a Complaint

For the purposes of this policy, a complaint is defined as follows:

  • A criticism addressed to Alpha Distinction by a complainant;
  • A report by a complainant of an actual or potential harm that a consumer has suffered or may suffer due to Alpha Distinction;
  • A request by a complainant for corrective action or compensation.

However, the following does not constitute a complaint:

  • An informal approach aimed at resolving a specific issue within the routine operations of Alpha Distinction without a formal complaint being filed.

If a consumer’s or complainant’s expression does not meet the definition of a complaint outlined above, any steps taken by Alpha Distinction to transfer the complaint to the appropriate person or entity should not be interpreted as being covered by this policy. This also includes the creation of a file by Alpha Distinction in response to such an expression.

Alpha Distinction, having business relationships with various partners, may choose to conduct internal or external investigations to assess its relationships with certain partners in the event of an expression or complaint.

Administrative Procedures

Any expression by a complainant or consumer that meets the definition of a complaint above must follow the prescribed process.

Receipt of the Complaint

A complainant wishing to file a complaint must do so in writing, addressed to the person responsible for handling complaints, at the following address: compliance@alphadistinction.com

If the complaint is received by an employee of Alpha Distinction, it must be promptly forwarded to Alpha Distinction for policy implementation.

For verbal complaints, a written summary must be prepared by the person who received the complaint.

Upon receipt of the complaint, Alpha Distinction must send an acknowledgment of receipt to the complainant, including the following information:

  • A summary of the complaint detailing the nature of the grievance, the alleged harm, and the corrective actions or compensations requested;
  • The contact details of Alpha Distinction;
  • The missing information needed for appropriate follow-up;
  • The deadline for providing the missing information, with a notice indicating that without this information, the complaint will be considered abandoned;
  • A copy of the complaint handling and dispute resolution policy;
  • A notice concerning the complainant’s right to request the transfer of their file to the AMF if dissatisfied with Alpha Distinction’s final response or the handling of their complaint;
  • A notice informing that the AMF may, at its discretion, offer dispute resolution services;
  • A statement specifying that filing the complaint with Alpha Distinction or the AMF does not interrupt the limitation period for civil remedies.

Creation of the Complaint File

Each complaint received by Alpha Distinction is handled separately, with the creation of a distinct file containing:

  • A copy of the written complaint;
  • In the case of an oral complaint, a copy of the summary prepared by the person who collected the complaint;
  • A complaint form summarizing:
    • The grievance made;
    • The alleged harm;
    • The corrective action or compensation requested;
  • The results of the complaint handling, the analysis conducted, and relevant documents;
  • The final response to the complainant, written and reasoned.

Complaint Handling Process

Within 10 days of receiving the complaint, Alpha Distinction must send an acknowledgment of receipt to the complainant.

Alpha Distinction must ensure that the complaint is handled and that the final response is sent within the later of the following two periods:

  • Within 30 days of sending the acknowledgment of receipt; or
  • Within 30 days of receiving the additional information requested in the acknowledgment of receipt.

In the case of complex complaints or those requiring detailed processing, rather than a final response, a notice informing the complainant of the progress and additional time required must be sent.

Handling Process:

Upon receipt of the complaint, Alpha Distinction decides whether to handle the file internally or delegate it to an employee. This choice, along with the name of the assigned person if applicable, is noted on the complaint form.

Whether handled internally or delegated, an acknowledgment of receipt must be sent to the complainant within 30 days of receipt.

Analysis:

The person responsible for the analysis assesses whether the complaint requires in-depth processing. They must notify the complainant of the estimated processing time and the progress of the analysis. This notice must be reasoned and kept in the complaint file. Depending on the importance of the complaint, this notice may be sent multiple times.

The person analyzing the complaint must review the details and, within a reasonable timeframe, obtain the version of the person subject to the grievance. They must also analyze relevant available or obtainable documents and document their analysis in the complaint file.

After analysis, working hypotheses are formulated but are not part of the complaint file.

Response:

If the person who analyzed the complaint is not the one responsible for the response, they must pass their hypotheses to the responding person, who drafts the response.

The response must be written, reasoned, and added to the complaint file. If it is final, this must be specified and include a mention regarding the complainant’s right to request the transfer of their file to the AMF if dissatisfied, as well as instructions for making this request.

If the response is not final, it must inform the complainant of the steps needed to obtain a final response.

Transferring the Complaint to the AMF

If the complainant wishes their complaint to be transferred to the AMF, they must inform the designated person in writing at the following address: Alpha Distinction Inc. 3445 Boulevard Laframboise, Suite 205 Saint-Hyacinthe, Quebec, Canada J2S 4Z8

Transfer requests cannot be made verbally or by email.

Upon receiving the request, the designated person must forward the complaint file to the AMF according to the established procedures, ensuring that irrelevant personal information and working hypotheses are removed from the file.

Application and Provincial Compliance

This complaint handling policy is designed to comply with the requirements of the Autorité des Marchés Financiers (AMF) of Quebec. However, Alpha Distinction acknowledges that specific rules and laws may also apply in Ontario and Alberta. Therefore, while this policy is primarily aligned with AMF requirements, it will be implemented in accordance with the laws and regulations in these other provinces, in compliance with the Financial Services Regulatory Authority of Ontario (FSRA) and the Alberta Insurance Council (AIC), as applicable.