Complaints Policy

AIM OF POLICY

This policy was established to provide oversight for the receipt of complaints, delivery of the acknowledgement of receipt and notice to the complainant, creation of the complaint file, transfer of the file to the Autorité des marchés financiers (AMF), if applicable, and compiling and filing an annual report with the AMF.

PERSON IN CHARGE

The Person in Charge acts as a respondent to the AMF and ensures that the Firm’s employees receive the training and necessary information to comply with this policy.

In addition to the duties outlined above, the Person in Charge is responsible for:

• Delivering an acknowledgement of receipt to the complainant
• Delivering the required notice to the complainant
• Transferring the file to the AMF at the complainant’s request
• Maintaining a register of complaints
• Submitting a biannual report to the AMF

COMPLAINT

To be admissible, the complaint must be filed in writing by the complainant. It may take the form of a letter, lawsuit or notice of a disciplinary complaint.

For the purposes of this policy, the complaint must contain one of the following three elements:

• a reproach against the Firm, one of its brokers or claims adjusters, or an employee ;
• the identification of real or potential harm that the complainant has sustained or may sustain ;
• a request for remedial action.

However, any verbal or written communication from the customer taking informal steps to correct a specific issue is not considered a complaint, provided that the issue is handled in the course of regular activities and the customer has not filed a formal complaint.

RECEIPT OF THE COMPLAINT

Customers who wish to file a complaint must do so in writing to the following address:

Lareau – Insurance Brokers Inc.

Attn: Philippe Lareau

707-4, Route 219, P.O. Box 1157

Napierville, QC

J0J 1L0

(450) 245-3322, ext. 386

1-888-LAREAU1

Fax: (450) 245-7538

Or by email at:

[email protected]

Any employee who receives a complaint must immediately forward it to the Person in Charge of applying this policy, who must acknowledge receipt of the complaint within five (5) working days. The acknowledgement of receipt of the complaint must contain the following information:

• A copy of this policy.
• A description of the complaint received, specifying the reproach against the Firm and/or its employee and the requested remedial action (or a copy of the complaint itself).
• The name and contact information of the Person in Charge of handling the complaint.
• For incomplete complaints, a notice requesting that additional information be sent to the Person in Charge within five (5) working days, failing which the complaint will be deemed to have been abandoned.
• A notice informing the complainant of their right to request a transfer of their complaint file to the AMF if they are not satisfied with the outcome or handling of their complaint, at least 15 working days after the required information has been received and no later than one year after receiving a response. The notice must also indicate that the AMF may offer mediation if the parties agree.
• A notice informing the complainant that mediation is an amicable dispute resolution process in which a third party (the mediator) works with the parties to help them come to a satisfactory agreement (each party pays half of the mediator’s fees and expenses).
• A reminder to the complainant that filing a complaint with the AMF does not interrupt the limitation period for civil remedies against the Firm.

CREATION OF THE COMPLAINT FILE

A separate file must be created for each complaint received. The file must contain the following elements:

1. The complainant’s written complaint, including at least one of the following three elements:

• the reproach against the Firm or employee
• the real or potential harm
• the requested remedial action

2. A copy of the acknowledgement of receipt or request for additional information sent to the complainant.
3. The outcome of the complaints handling process (analysis and supporting documents).
4. A copy of the Firm’s final response, including the reasons for the response, sent in writing to the complainant.
5. A copy of any document sent by the complainant to the Person in Charge.

HANDLING THE COMPLAINT

Upon receipt of a complaint, the Person in Charge or their designate must conduct an investigation.

The complaint must be handled within fifteen (15) working days of receiving all necessary information.

Following the investigation, the Person in Charge or their designate must send the complainant the Firm’s final response, including the reasons for the response.

Reference to Lloyd’s and Liberty

When the insured writes to the Lloyd’s Canada office, Lloyd’s Canada will forward the complaint to the broker who placed the business with Lloyd’s. The broker is responsible for responding directly to the insured, with a copy to Lloyd’s Canada ([email protected]) within 10 business days. If the insured remains dissatisfied with the first-step response, they must inform the Lloyd’s Canada office in writing within 10 business days of receiving the first-step response. Subsequently, the Lloyd’s Canada office will forward the complaint, along with the first-step position, to the Lloyd’s Claims Team, which will review the complaint and respond directly to the insured with a final response letter.

When a complaint is forwarded to the Lloyd’s Claims Team, they will have the remaining balance of 56 calendar days to provide a final response letter to the insured. However, if there are unforeseen circumstances preventing the Lloyd’s Claims Team from providing a final response letter within the 56 days, they must inform the insured that the case is still under review. If the insured is not satisfied with the final response letter from the Lloyd’s Claims Team, they have the right to have the complaint reviewed by the Autorité des marchés financiers (AMF). In total, the insurer has 56 calendar days from the moment Lloyd’s Canada forwards the complaint to the broker until the final position letter is sent to the insured by the Lloyd’s Claims Team.

For all complaints related to a Liberty policy, a copy of the client’s complaint file, containing all client information, must be immediately sent to the Liberty underwriters. If the request was made in a language other than English, it must be translated and sent to the following email address: [email protected]. A copy of the response must be sent to the Liberty underwriters, at [email protected], as soon as it is issued by the complainant.

TRANSFER OF THE FILE TO THE AMF

If the complainant is not satisfied with the outcome or the Firm’s examination of their complaint, they may request that the Firm transfer their complaint file to the AMF.

The complainant may only exercise this right once the deadline of 15 working days to obtain a final response has passed and no later than one year after receiving this response.

The file transferred to the AMF must contain all documents in the Firm’s possession related to complaint file. The Firm is not required to provide the file from their professional liability insurer.

CREATION AND MAINTAINANCE OF A REGISTER

The Firm must create a register of complaints for the purposes of applying this policy. The Person in Charge is responsible for keeping it up to date.

Any complaint that is made in writing and falls within the definition set out above must be recorded in the register. For greater clarity, this must be done if the complaint is admissible, regardless of the level of response required.

AMF Biannual Report

The Person in Charge must submit a report to the AMF detailing the number and nature of complaints received, categorized according to the register established in Q1 for the previous year.

EFFECTIVE DATE

This policy came into effect on May 15, 2006 and was amended on June 12, 2024.

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