1. Objective of the Policy

The objective of this policy is to establish a clear, accessible, and compliant procedure for handling all client complaints received by Coigne Capital Inc. (“the Firm”). This policy ensures that complaints are managed in a manner that is fair, transparent, and in full compliance with regulatory standards, particularly those set forth by the Autorité des marchés financiers (AMF) and other relevant regulatory bodies. The policy governs the receipt, acknowledgment, management, resolution, and documentation of complaints, and where necessary, the escalation of unresolved issues to the AMF. The Firm is committed to fostering trust and maintaining high standards of client service through diligent complaint management.

2. Scope of the Policy

This policy applies to all employees, representatives, brokers, and third-party service providers engaged by Coigne Capital Inc. It covers all complaints related to the Firm’s activities, including but not limited to, wealth management, insurance brokerage, investment advisory, and any other financial services provided by the Firm.

3. Responsible Person

The overall responsibility for the implementation and adherence to this policy lies with Sergio Paier, President of Coigne Capital Inc. As the Responsible Officer, Mr. Paier ensures that the Firm’s complaint management processes are in line with legal and regulatory requirements.

In his role, Dominique Vaillancourt, as a Manager, is tasked with the day-to-day responsibilities of ensuring that employees and brokers are well-trained and informed about the complaint-handling process. His specific duties include:

• Acknowledgment of Complaints: Issuing an acknowledgment of receipt to the complainant within five working days.
• Complaint Handling: Conducting investigations, managing the complaint file, and ensuring that complaints are addressed effectively and within the stipulated timeframe.
• Regulatory Compliance: Ensuring that complaints involving investments and mutual funds are communicated to WhiteHaven Securities, and those involving insurance are communicated to QFS Qualified Financial Services Inc., within five working days.
• Escalation to AMF: Facilitating the transmission of complaint files to the AMF upon the complainant’s request.
• Record-Keeping: Maintaining a detailed register of all complaints received.
• Reporting: Preparing and submitting semi-annual reports to the AMF as required by law.

4. Definition and Admissibility of a Complaint

A complaint is defined as any expression of dissatisfaction, whether oral or written, made by a client or potential client regarding a product or service provided by Coigne Capital Inc. An admissible complaint typically includes:

• A criticism or dissatisfaction with a product or service.
• An allegation of actual or potential harm or prejudice.
• A request for corrective measures.

It is important to note that casual expressions of dissatisfaction or informal grievances that do not require corrective action do not constitute admissible complaints under this policy.

5. Receipt of the Complaint

Clients may submit complaints in writing via mail, email, or fax to:

Sergio Paier, President
Coigne Capital Inc.
Toll-free: 1-888-333-0398
Direct: 438-800-8514
Email: info@coignecapital.ca

The responsible person acknowledges receipt of the complaint within five working days, providing the complainant with a clear outline of the complaint-handling process, including expected timelines and points of contact.

6. Creation of the Complaint File

Upon receipt, each complaint must be assigned a unique reference number and documented in a separate file. This file should include:

• A copy of the original complaint.
• Correspondence related to the complaint.
• Records of any communications with the complainant.
• Investigation notes and findings.
• The Firm’s final written response.

This ensures that every aspect of the complaint is thoroughly documented, allowing for traceability and ease of access during reviews or audits.

7. Processing of a Complaint

Once a complaint is received, the responsible person or an appointed representative will conduct a thorough and impartial investigation. This process may involve gathering additional information from the complainant, consulting with relevant employees or brokers, and reviewing any pertinent documentation.

Investment and Mutual Funds Complaints:
For complaints related to investments or mutual funds, Coigne Capital will notify WhiteHaven Securities, the broker-dealer for these products, within five working days. WhiteHaven Securities will be involved in the investigation and resolution process as required.

Insurance Complaints:
For complaints related to insurance products, Coigne Capital will notify QFS Qualified Financial Services Inc., the Managing General Agent (MGA) utilized by the Firm, within five working days. QFS will assist in the investigation and resolution of the complaint.

8. Response to the Complainant

The Firm’s final written and reasoned response will be sent to the complainant within one month of receiving all necessary information. This response will include:

• A summary of the complaint.
• Details of the investigation conducted.
• The Firm’s conclusions and any corrective measures offered.
• Information about the complainant’s right to escalate the complaint to the AMF if dissatisfied with the response.

9. Escalation to the AMF

If the complainant is unsatisfied with the Firm’s response, they may request that the file be forwarded to the AMF for further review. The Firm is obligated to comply with this request and must submit all relevant documentation to the AMF within the timeline stipulated by the regulatory body.

10. Complaints Register

The complaints register, maintained by the responsible person, is a critical tool for ensuring that all complaints are logged, monitored, and tracked efficiently. The register must include:

• The date of receipt.
• Complainant details.
• Nature and description of the complaint.
• Steps taken to address the complaint.
• Final resolution and date of closure.

This register is subject to regular review and audit to ensure ongoing compliance.

11. Semi-Annual Report

In compliance with regulatory requirements, the Firm submits a semi-annual report to the AMF, summarizing all complaints received during the reporting period. This report includes statistics on the number of complaints, the nature of complaints, resolution outcomes, and any trends identified.

12. Information and Training for Employees

All employees and brokers of the Firm are required to be familiar with the complaints management policy. Regular training sessions are conducted to ensure that all personnel understand the procedures, their roles in the complaint-handling process, and the importance of timely and effective resolution. Training also focuses on enhancing client relations skills to prevent complaints from arising.

13. Confidentiality

Coigne Capital Inc. is committed to protecting the confidentiality of all information related to complaints. Personal and sensitive data is handled in accordance with the Firm’s privacy policy and applicable data protection laws. All records pertaining to complaints are securely stored and accessed only by authorized personnel.

14. Client Communication

Clients will be kept informed throughout the complaint-handling process. This includes:

• Acknowledgment of receipt.
• Regular updates on the investigation status.
• A clear and detailed final response.

This ensures transparency and fosters trust between the Firm and its clients.

15. Continuous Improvement

The Firm is dedicated to continuous improvement in complaint management. Feedback from complaints is systematically analyzed to identify areas for improvement in products, services, and internal processes. Lessons learned from complaints are incorporated into training programs and operational procedures to enhance the Firm’s overall service quality.

16. Monitoring, Review, and Policy Updates

This policy is reviewed annually by the responsible person to ensure it remains effective, relevant, and compliant with current regulations. The policy may also be updated more frequently in response to changes in legislation, regulatory guidance, or internal processes. Employees will be informed of any changes, and updated training will be provided as necessary.

17. Regulatory Compliance

Coigne Capital Inc. ensures that all complaints are handled in strict compliance with relevant laws and regulations governing the financial services industry in Canada and the province of Quebec. The Firm adheres to the guidelines and best practices established by the AMF and other regulatory bodies, ensuring that the rights and interests of clients are protected at all times.

18. External Dispute Resolution

In situations where a complaint cannot be resolved internally to the satisfaction of the client, Coigne Capital Inc. will inform the client of their right to seek external dispute resolution through appropriate channels, such as the Ombudsman for Banking Services and Investments (OBSI) or other relevant bodies, depending on the nature of the complaint.

19. Documentation Retention

All complaint-related documentation is retained for a minimum period of seven years from the date of resolution or as required by law. This ensures that the Firm can provide evidence of compliance and proper complaint handling if requested by regulatory bodies during audits or investigations.

Conclusion

By implementing this comprehensive Complaints Management Policy, Coigne Capital Inc. reaffirms its commitment to maintaining the highest standards of client service and regulatory compliance. The Firm recognizes the importance of effective complaint management in building client trust, improving services, and ensuring adherence to industry regulations.