Complaints Handling Policy

Our clients and partners deserve the best service possible, and we are committed to providing prompt, respectful and efficient support, by courteous, knowledgeable, and caring professionals. Our complaint handling policy mission is to treat each dispute/complaint in all fairness, impartiality, and clarity, whether it involves our team, the distribution of our products and services or the protection of personal information.

Defining a Complaint

A complaint is defined as the expression of at least one of the following elements that persists after being considered and examined at the operational level capable of deciding on the matter:

• a reproach against an organization;
• the identification of a real or potential harm that a consumer has experienced or may experience;
• a request for a remedial action.

Any requests made or disputes communicated that fits into the above definition, will be handled promptly and efficiently by our management team, to provide an adequate solution.

How to Submit a Complaint

Our management team is ready to assist in resolving any disputes, or dissatisfaction by a consumer, in a clear, unambiguous, and easy to understand matter. If the consumer remains dissatisfied with the resolution provided by the person responsible, a complaint can be submitted in writing.

A complaint can be submitted through our form below. Our management team will be pleased to provide any guidance in filling out and understanding the form, as part of our commitment in facilitating the process to the complainant.

Communication Process

The person responsible for handling complaints will provide an acknowledgment of receipt to the complainant within 48 hours of receipt of a complaint. The person responsible will carry out the examination of the complaint within a reasonable timeframe and make a final and conclusive decision and communicate such decision with the complainant. They may also submit the file to the authority, at the request of the complainant as well as report it to the authority through their designated reporting platform.

Should a complaint be incomplete or missing additional information for analysis, a request will be made to the complainant, and any further investigation will necessarily cease until such information is provided.

The complainant shall be informed promptly of the progress of the investigation as well as the estimated time of the resolution.

Investigation and Resolution

The person responsible for handling complaints will investigate impartially the facts involving the complaint which includes and may not be limited to documentations, communications (email, telephone recordings, mail) to ensure its validity, authenticity, and relevance to the complaint. They may contact third parties, with the permission of the complainant, for further analyses, while ensuring the protection of the public and personal confidential information related. They will then decide on an appropriate action and reach a resolution to the complaint, in most cases, within maximum 60 days of receipt of the complaint. If the complainant, after receiving the resolution, provides additional information which could alter or influence it, the investigator(s) will determine if further consideration is triggered.

The resolution will be provided to the complainant along with details which led to such resolution, including any deadlines given, in order to reach an agreement with the complainant. The resolution will be communicated in a clear, easy to understand matter, to prevent any misleading, misunderstanding or confusion. It will also include any escalation options available to the complainant (i.e. reporting to any higher authority).

Reporting to the Authority

In the event that the complainant is not satisfied with the result of the processing of a complaint, or the processing itself, the complainant has the option to request the complaint be escalated to ask the person responsible to transfer the complaint to the Authority. The file transferred to the Authority will consist of all the documents relating to the complaint. The transfer must be made to the Authority within 30 days of the complainant’s request.

Documentation and Improvement

We are committed to handling all complaints in the utmost confidentiality and are supervised by our Privacy and Compliance Officer. We record all our complaints internally for auditing, tracking, reporting, and training purposes. Such records will be used for further improvements on our processes based on the feedback and analysis provided by all parties involved.

Policy effective date: August 14, 2025