Complaints Management Policy

Complaint processing and dispute resolution policy – Brightstone Trust Company

Summary of Our Complaint Processing and Dispute Resolution Policy

The purpose of this policy is to ensure that complaints received from our clients are processed fairly.

The policy is also intended to help improve our services by enabling us to identify causes common to the complaints we receive and implement solutions to correct problem situations.

What we consider a complaint?

A complaint expresses a client’s reproach or dissatisfaction in respect of the services or products we offer and the client’s expectation that we take action to address the complaint

For example, when they expect compensation or an apology from us or ask us to take steps to address or put a stop to the situation giving rise to the complaint.

How to file a complaint

Our clients may file a complaint with one of our representatives; by phone, e-mail or mail; or by completing the form from the Autorité des marchés financiers (AMF). We assist clients in properly filing their complaints.

Contact us

Phone: 514-845-9165

E-mail: avis@brightstonefinancial.ca

Mail: 1000 Sherbrooke West, suite 1900, Montreal, Quebec, H3A 3G4

*Our offices are open Monday to Friday, from 8:30 a.m. to 5 p.m.

Our clients may contact us at any time to obtain information on how we process complaints or how they can file a complaint or inquire about a complaint they have made.

Steps in the complaint process

We may follow a simplified process for certain complaints. This process is explained below. If the complaint cannot be resolved to the client’s satisfaction under the simplified process, the complaints officer or a person under the complaints officer’s supervision takes charge of the complaint in order to complete the process and send a written final response to the client.

1. We acknowledge receipt of the complaint

We acknowledge receipt of a client’s complaint in writing within 10 days of receipt.

2. We analyze the complaint

We make sure we understand what they are expecting from us. The person who analyzes the complaint must obtain all the information required to process the complaint by requesting additional information from the client.

3. We provide a written final response

A final response is provided in writing within 60 days. In our response to the client, we explain how we analyzed the complaint and what led to our response and the proposed solution to the complaint.

Communications with the client do not end when we provide our response. If the client contacts us, we continue to respond by, among other things, answering their questions and following up on their comments.

Extension of the period for providing our response

The person analyzing the complaint may find that the complaint is taking more time or is more complex to process than anticipated and may therefore determine that additional time is required for the analysis. The additional time may not exceed 30 days. In such an event, the person analyzing the complaint will notify the client in writing on or before the date the response was expected to be provided to them.

4. Assessment of the offer and resolution of the complaint

When we propose a solution to a client complaint, we give the client a reasonable amount of time to assess our offer. The amount of time has to reflect the complexity of the complaint and provide the client with sufficient opportunity to seek advice for the purpose of accepting or rejecting our offer or presenting a counteroffer.

Once we reach an agreement with the client to resolve their complaint, we must give effect to the offer within 30 days. We may agree upon a different time period with the client provided it is in the client’s interest.

5. Examination of the complaint record by the AMF

We create a record for each complaint and make sure it remains current by adding the relevant documents and information to it as the complaint is being processed.

A client has the right to request to have their complaint record examined by the AMF if they are not satisfied with how we handled the complaint or the response we provided. A client can ask us to transfer their complaint record to the AMF or make the request directly to the AMF. In either case, we make sure their complaint record is sent to the AMF within 15 days following receipt of the request.

Simplified process for certain complaints

We may follow a simplified process for certain complaints. This process is used for complaints that we can resolve to the satisfaction of clients within 20 days.

We consider a complaint to be resolved to the satisfaction of the client when the client accepts our proposed solution to their complaint or when the explanations we provide are sufficient to resolve the complaint.

Under the simplified process, complaints may be referred to a member of our client service team. The person that handles the complaint can process it verbally (e.g., in a phone call).

If the complaint cannot be resolved to the client’s satisfaction under the simplified process, the complaints officer or a person under the complaints officer’s supervision takes charge of the complaint in order to complete the process and send a written final response to the client.

*The time we take to try to resolve the complaint under the simplified process does not affect our obligation to provide a written final response within the required time periods.

There’s one small difference from the French to keep in mind. The French says you’ll explain the reasons for an extension in the written notice, but the English policy doesn’t say that, so it isn’t included here. If you want the two versions to match exactly, you could add: *”We will explain the reasons for the additional time.”