Policy on complaints handling procedures
1. Complaints Handling – Effectiveness, Efficiency and Accountability
This Policy sets out the procedures that apply to David Forest Financial Services Ltd., and FOREST. where applicable.
FOREST senior management supports the procedures set forth in this Policy. FOREST senior management will:
- appoint the Complaints Officer;
- provide support for the resources necessary to ensure that the Complaints Officer is adequately trained and has the necessary authority to resolve or recommend resolutions to complaints where possible; and
- endorse measures to support (i) broad company wide training so that employees are familiar with these procedures; and (ii) implementation of methods to facilitate analysis of historical information, in order to track compliance issues and/or identify potential compliance risks.
FOREST. is committed to dealing with and resolving complaints in a timely manner. The Complaints Handling Procedures are set forth below. FOREST. is expected to inform complainants about these procedures, to keep complainants current about the status of their complaints at specific points during the complaint-handling process and to identify and highlight circumstances in which an extension of the timeline may be warranted.
2. What constitutes a complaint?
For the purpose of this policy, a complaint is the expression of at least one of the following three elements by a customer or other person or entity external to FOREST.:
- A reproach against ;
- The identification of real or potential harm that a complainant has sustained or may sustain; or
- A request for remedial.
Informal steps to correct a specific problem will not be considered as a complaint, provided the problem is resolved as part of FOREST’s normal business activities and the consumer has not registered a formal complaint.
3. Complaints Handling Procedures:
- A party may make a complaint in writing, in person, by email or by The party making the complaint (the “complainant”) shall first contact the person with whom he or she had the interaction that gave rise to the complaint. It is suggested that as much information as possible be supplied, including supporting documentation. If FOREST. does not have all of the necessary information that it needs then this will impact the complaint process. At each step, the FOREST. employee will acknowledge receipt of the complaint.
- If the complaint remains unresolved, the person named in #1 above shall inform his/her immediate manager (the “Manager”). The Manager shall attempt to resolve the complaint.
- If the complaint remains unresolved, the Manager shall offer to escalate the matter to the Complaints Officer. Alternatively, the complainant may contact the Complaints Officer directly (contact information in section 4 below). The role of the Complaints Officer is also set forth below.
- The Complaints Officer shall create a separate file for each complaint. The file must contain the following:
- The written complaint and its three elements (the reproach against the registrant, the real or potential harm and the requested remedial action);
- The outcome of the complaint examination process (the analysis and supporting documents); and
- The final written response to the complainant with justifying reasons.
- Within five (5) days after a complaint is registered in the complaints register, the Complaints Officer must send the complainant a notice stating the complaint registration date and the complainant’s right to have the complaint record examined as outlined in Section 4 below.
- Within ninety (90) days or less when possible, following receipt of all of the applicable information and documentation relevant to the complaint at the second level of complaint handling, the complainant shall be provided with a substantive written response (if the complainant prefers this can be by way of email) to his or her complaint that includes, at a minimum:
- FOREST’s final decision/offer in response to the complaint, including appropriate details and explanations regarding how the final decision was reached; and
- the complainant’s right to escalate the complaint (to those bodies noted in section 4 below of which FOREST. is a member) upon receipt of FOREST’s final decision, if the complaint has not been resolved to the complainant’s satisfaction or if the complaint has not been dealt with within the above said ninety (90) days. If FOREST takes longer than the said ninety (90) days the complainant shall have the right to escalate the matter to the said bodies and FOREST shall advise the complainant of such right.
7. If the complaint remains unresolved, the complainant shall be advised how to contact the organizations referred to in section 4 below.
4. Role of Complaints Officer and Contacts
The role of the Complaints Officer is to provide a forum for our customers and other parties to voice concerns following interactions with our employees. These concerns could range from the manner in which they were addressed to the handling of insurance subscription.
The Complaints Officer will assess whether the correct internal process was adhered to, ensure that the party lodging the complaint has been given every opportunity to be fully and fairly heard and provide a written response setting out his/her findings. The Complaints Officer shall have discretion to refer the matter back (with recommendations if he/she so chooses) to either the first FOREST. employee that had an interaction with the complainant or to that employees Manager.
155 René-Lévesque Blvd W, Suite 2026, Montreal, Quebec, H3B 4S5
Telephone: 514 866-3838 ext. 113
In the province of Quebec, if a complainant is not satisfied with the outcome or with the examination of the complaint, he may ask FOREST., at any time, to transfer the file to the Autorité des marches financiers (hereafter referred as the «AMF»). The AMF can be contacted at one of the following locations:
Place de la Cité, tour Cominar
2640, boulevard Laurier, bureau 400 Québec (Québec) G1V 5C1
Telephone: 418 525-0337
Fax: 418 525-9512
800, Square Victoria, 22nd floor
C.P. 246, tour de la Bourse Montréal (Québec) H4Z 1G3 Telephone: 514 395-0337
Fax: 514 873-3090
Toll Free: 1 877 525-0337
5. Complaints Reporting Procedure:
FOREST. reports to certain entities with respect to reportable complaints (based on applicable legislation) pursuant to the terms of the attached Schedule entitled “Complaints Reporting Procedure”, as such Schedule may be updated from time to time.
COMPLAINTS REPORTING PROCEDURES SCHEDULE
FOREST. reports to the following entities with respect to complaints:
- AMF on a semi-annual basis;
- Participating Authorities for the Rest of Canada (PARC) on a semi-annual basis.