Complaint handling policy

1. Policy Objective

The objective of the Complaint Handling and Dispute Resolution Policy is to create efficient and fair procedures to handle complaints received by La Turquoise, Insurance Brokers, La TurquoisePro, cabinet en assurance de dommages and ProtectPro (the “Company”). The aim is to streamline receipt of complaints, delivery of the acknowledgment of receipt and notices to the complainant, as well as create complaint files, and where applicable, submit the file to Autorité des marchés financiers (“AMF”), and compile complaints in order to prepare and file a report twice a year.

2. Persons in Charge

The persons in charge of applying the Policy within the Company is Sonia Mercier, Vice-President, Business Lines. 

She shall act as respondent with the AMF, provide training to employees and, more specifically, make sure the employees receive the information required to ensure the Policy is respected. 

The person in charge shall also:

• Send an acknowledgement of receipt to the complainant.
• Transfer the file to the AMF, at the complainant’s request.
• File a report twice a year with the AMF, using the Compliant Reporting System. 
   

3. Complaints

For the purposes of the Policy, a complaint is the expression of at least one of the three following issues which remain after being examined and handled at the appropriate decisional level:

• A reproach about an employee or a brokerage firm.
• Identification of a potential or actual prejudice, which a consumer has or may have suffered.
• Request for remedial action.

An initial expression of dissatisfaction by a consumer, whether in writing or not, is not considered a complaint when this issue is resolved in the normal course of the Company’s activities.

4. Receipt of the Complaint

Consumers who wish to file a complaint may do so by contacting one of the persons in charge of the Policy whose name and sector appear in Article 2. 

By mail: La Turquoise, 104, Dubois street, Saint-Eustache, QC, J7P 4W9

              La TurquoisePRO , 481 Road 131, Joliette, QC  J6E 3Z6

By phone:   450-472-5332 / 1 800-363-6308 (toll-free)

Employees who receive a complaint, as defined in Article 3, must, upon receipt, forward it to the person in charge of applying this Policy. 

The person in charge must acknowledge receipt of the complaint within ten (10) business days. The acknowledgement of receipt must contain at least the following information:

• A description of the complaint, specifying the potential or actual prejudice, the reproach made about the employee or the Company, and the remedial action requested.  
•  The name and contact information of the person in charge of handling the complaint.  
• In the case of an incomplete complaint, a notice requesting more information to which the complainant must reply within ten (10) days, failing which the complaint will be deemed to have been abandoned.
• A copy of the Policy.
• A notice informing the complainant of his/her right to request the file be transferred to the AMF, if the complainant is not satisfied with the result or with how the complaint was handled. The notice must also mention that the AMF may offer mediation, an amicable settlement, if deemed appropriate and if the parties agree. 
• A notice informing the complainant that filing a complaint with the AMF does not interrupt the prescriptive period for civil remedies against the Company.  

5. Creating the complaint file

A separate file must be created for each complaint. 

The file must contain:

• The written complaint or a full description of the complaint if it was made verbally, including one of the three issues raised (reproach against the employee or Company, the potential or actual prejudice and the remedial action requested). 
• The outcome of the complaint handling process (analysis and supporting documents).
• A copy the final written response to the complainant with justifying reasons.

6. Examining the complaint

On receipt of a complaint, the Company must carry out an investigation.

The complaint must be examined within a reasonable period of time, namely within thirty (30) business days of receipt of all the information required to examine it. 

At the end of the investigation, the person in charge must send the complainant a final written reply with justifying reasons. 

7. Transferring the file to the AMF

If the complainant is not satisfied with the outcome of the complaint, or the process itself, he/she can ask the Company to transfer the complaint file to the AMF. 

This right can only be exercised by the complainant at the end of the period of time specified to obtain a final reply, without exceeding a period of one (1) year as of the date the reply was received.

The file transferred to the AMF must include all of the information related to the complaint.

The Company is responsible for complying with the rules governing the protection of personal information.  

8. Bi-annual report

Twice a year, regardless whether any complaints were received, the person in charge must file a report with the AMF, using the CRS, detailing the number and nature of the complaints received. The reporting periods are:

• No later than July 30, for data collected between January 1 and June 30
• No later than January 30, for data collected between  July 1 and December 31