1 | Purpose
This Policy sets out a transparent, fair, and fully compliant process for receiving, investigating, resolving, and, where necessary, escalating all client complaints received by Coigne Capital Inc. (“the Firm”). It reflects the requirements of the Autorité des marchés financiers (“AMF”) and any other regulatory bodies governing our activities in Québec and Canada.
2 | Scope
The Policy applies to every director, officer, employee, licensed representative, independent broker, and third-party service provider acting on behalf of the Firm in connection with:
Wealth-management services
Insurance brokerage activities
Investment advice and any other financial or ancillary services we provide
3 | Governance and Key Roles
| Role | Principal Holder | Core Responsibilities |
|---|---|---|
| Policy Owner | Sergio Paier, President | • Maintain & update the Policy • Ensure resources for compliant complaint handling |
| Complaints Manager (may be delegated) | Sergio Paier | • Acknowledge, log, and investigate complaints • Coordinate with WhiteHaven Securities (investments) and QFS Qualified Financial Services Inc. (insurance) within 5 business days • Deliver a Final Written Decision within 60 days (maximum 90 days in exceptional cases) blg.com • Report unresolved files to the AMF if requested by the client |
4 | What Constitutes an Admissible Complaint
A “complaint” is any written or verbal expression of dissatisfaction that:
alleges real or potential financial harm, prejudice, or misconduct; and
explicitly or implicitly seeks corrective action or compensation.
Informal comments that do not request redress are treated as feedback and logged separately for service-quality monitoring.
5 | How Clients Can Complain
Clients may lodge complaints in writing or verbally via:
Email: info@coignecapital.ca
Mail / Fax: Coigne Capital Inc., Attn: Complaints Manager, 3773 Boul. Côte-Vertu, Bureau 460, Saint-Laurent, QC H4R 1P8
Phone: Toll-free 1 – 888 – 333-0398 | Direct 438 – 800-8514
6 | Process Overview
| Step | Timeline | Action |
|---|---|---|
| 1. Acknowledge Receipt | ≤ 5 business days | • Confirm complaint received • Provide name & contact of Complaints Manager • Outline next steps and deadlines |
| 2. Open Complaint File | Immediate | • Assign unique reference number and enter in Complaints Register (secure, searchable) |
| 3. Investigate | Ongoing | • Collect documents & witness statements • Engage WhiteHaven Securities (investments) or QFS (insurance) within 5 business days • Maintain impartiality and keep client informed |
| 4. Final Written Decision | ≤ 60 days† | • Summarise complaint, findings, outcome, corrective measures or compensation • Explain right to escalate to the AMF and, where applicable, OBSI/CIRO |
| 5. Escalation | On request | • Forward complete file to the AMF within 30 days of client request • Cooperate with any external dispute-resolution body |
| †May extend to 90 days only in exceptional, documented circumstances. blg.com |
7 | Register, Retention & Reporting
Register: All data fields mandated by the Regulation—including dates, nature, product line, outcome—are maintained in a secure digital log.
Retention: Files are kept ≥ 7 years after closure.
Semi-Annual / Annual Reporting:
Investment & mutual-fund files are reported through CIRO/ComSet, then forwarded automatically to the AMF.
Insurance and other files are reported to the AMF via its E-Services portal between March 1 and May 1 each year, covering the preceding calendar year. lautorite.qc.ca
8 | Employee Training & Awareness
All personnel receive annual compliance training covering:
How to recognise and log a complaint
Time limits and communication standards
Privacy and record-keeping obligations
Completion is tracked in the Firm’s LMS; refresher sessions are provided when regulations change.
9 | Privacy & Confidentiality
Complaint files contain personal and sometimes sensitive financial information. Processing is conducted strictly under:
PIPEDA (federal) and Québec’s Act Respecting the Protection of Personal Information in the Private Sector; and
the Firm’s internal Privacy & Data-Protection Policy.
Only authorised staff may access complaint records.
10 | Continuous Improvement
Complaint trends are reviewed quarterly by senior management. Root-cause analysis findings feed into:
product or process enhancements
staff coaching
risk-management reporting
11 | Review Cycle
The Policy is reviewed annually (or sooner if laws change) by the President and Compliance Officer. Material revisions are approved by the Board of Directors and circulated to all staff.
12 | External Dispute Resolution
If a complainant remains unsatisfied after receiving our Final Written Decision, we inform them of the following free options, depending on product line:
AMF Complaint Examination Service (all Québec financial-sector matters)
OBSI (investment matters outside Québec jurisdiction or as required)
CIRO – Investor Complaint Resolution Program (for CIRO-member dealer activities)
Approved by: Sergio Paier, President & Policy Owner
Adopted on: 12 June 2025
Next scheduled review: June 2026
By adhering to this Policy, Coigne Capital Inc. reinforces its commitment to client trust, regulatory compliance, and continuous service excellence.
