Coigne Capital Inc.’s Complaints Management Policy

1. The objective of the Policy

This Policy establishes a transparent, compliant, and accessible procedure for handling all client complaints from Coigne Capital Inc. (“the Firm”). The Policy ensures that all complaints are managed fairly, transparently, and fully compliant with regulatory standards set by the Autorité des marchés financiers (AMF) and other relevant regulatory bodies. This Policy governs the receipt, acknowledgment, management, resolution, documentation, and, where necessary, escalation of complaints to the AMF. Coigne Capital Inc. is committed to upholding 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 client complaints related to the Firm’s activities, including but not limited to:

• Wealth management
• Insurance Brokerage
• Investment advisory
• Any other financial services provided by the Firm

3. Responsible Person

The responsibility for implementing and adhering to this Policy lies with Sergio Paier, President of Coigne Capital Inc. Mr. Paier, who ensures that all complaint management processes comply with legal and regulatory requirements. Additionally, Sergio Paier, as Manager, oversees day-to-day complaint handling, ensuring compliance, timely response, and effective resolution.

Specific duties include:

• Acknowledgment of Complaints: Acknowledging receipt of complaints within five working days.
• Complaint Investigation and Handling: Conducting investigations, managing the complaint file, and ensuring complaints are resolved within the required timeframe.
• Regulatory Compliance: Reporting investment-related complaints to WhiteHaven Securities and insurance-related complaints to QFS Qualified Financial Services Inc. within five working days.
• Escalation to AMF: Facilitating escalation to the AMF upon a client’s request if dissatisfaction persists after resolution attempts.
• Record-Keeping and Reporting: Maintaining a complaint register and preparing semi-annual reports for the AMF.

4. Definition and Admissibility of a Complaint

A complaint is defined as any expression of dissatisfaction regarding a product or service provided by the Firm, typically involving:

• Criticism or dissatisfaction with a product or service
• Allegation of harm, prejudice, or misconduct
• Request for corrective action or redress

Casual expressions of dissatisfaction or grievances not requiring formal 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: [email protected]

Acknowledgment of receipt will be issued within five working days, outlining the complaint handling process, estimated timelines, and a point of contact.

6. Creation of the Complaint File

Each complaint will be assigned a unique reference number and documented in a separate file, which will include:

• A copy of the original complaint
• Correspondence with the complainant
• Records of all communications
• Investigation notes and findings
• The final written response from the Firm

This ensures transparency, traceability, and compliance with regulatory audits.

7. Processing of a Complaint

Upon receiving a complaint, the responsible person or an appointed representative will conduct a thorough and impartial investigation, which may include gathering additional information from the complainant, consulting with relevant employees or brokers, and reviewing documentation.

• Investment and Mutual Funds Complaints: Coigne Capital will notify WhiteHaven Securities within five working days. WhiteHaven Securities will assist in investigating and resolving the complaint.
• Insurance Complaints: Coigne Capital will notify QFS Qualified Financial Services Inc. within five working days. QFS will assist in the investigation and resolution of insurance-related complaints.

8. Response to the Complainant

Within one month of receiving all necessary information, the Firm will send a final written response to the complainant. The response will include:

• A summary of the complaint
• Details of the investigation
• 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. Coigne Capital will provide the AMF with all relevant documents and details within the required timeframe.

10. Complaints Register

The responsible person will maintain a complaints register that will include the following:

• Date of receipt
• Complainant’s details
• Nature of the complaint
• Steps taken to address the complaint
• Final resolution and closure date

The register will be regularly reviewed to ensure compliance with regulatory standards and continuous improvement in complaint handling.

11. Semi-Annual Reporting

As required by law, Coigne Capital will submit a semi-annual report to the AMF summarizing all complaints received during the reporting period. The report will include:

• Number of complaints received
• Nature of the complaints
• Resolution outcomes
• Any trends or areas of concern

12. Information and Training for Employees

All employees, brokers, and Coigne Capital representatives must know this Policy. Regular training will ensure employees understand their roles in the complaint-handling process and have the necessary client relations skills to address complaints effectively.

13. Confidentiality

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

14. Client Communication

Clients will be informed throughout the complaint-handling process. Communication will include:

• Acknowledgment of receipt of the complaint
• Regular updates on the investigation’s progress
• A clear final written response detailing the resolution

This approach ensures transparency and fosters trust between Coigne Capital and its clients.

15. Continuous Improvement

The Firm is dedicated to continuous improvement. Feedback from complaints will be systematically analyzed to identify areas for improvement in products, services, and internal processes. Lessons learned will be incorporated into employee training and operational procedures to enhance service quality.

16. Monitoring, Review, and Policy Updates

The responsible person will review this Policy annually to ensure it remains effective, compliant, and aligned with current regulations. It may also be updated more frequently, if necessary, due to changes in legislation, regulatory guidance, or internal processes. Employees will be notified of any changes, and updated training will be provided.

17. Regulatory Compliance

Coigne Capital ensures that all complaints are handled strictly by Canada and Quebec’s relevant laws and regulations governing financial services. The Firm follows the guidelines the AMF and other applicable regulatory bodies set forth to ensure clients’ rights are always protected.

18. External Dispute Resolution

In cases where complaints cannot be resolved internally to the client’s satisfaction, Coigne Capital will inform clients 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 documentation will be retained for at least seven years from the resolution date or as required by law. This ensures compliance with regulatory audits and investigations if requested.

Conclusion

By implementing this comprehensive Complaints Management Policy, Coigne Capital Inc. reaffirms its commitment to maintaining the highest standards of client service, regulatory compliance, and trust. Complaint management is critical in enhancing client relations, improving services, and ensuring adherence to financial industry regulations.