Name of the Firm Covered by This Policy
Bravia Gestion Patrimoine Inc., hereinafter referred to as "the firm."

 

Application of the Policy

As a firm specializing in life insurance, the firm is responsible for handling complaints lodged against its representatives who are formally affiliated with it as per the law.

This policy, therefore, applies to all representatives of the firm.

 

Purpose of the Policy

The purpose of this policy is to establish a fair and free procedure for processing complaints received regarding a representative.

It specifically aims to regulate the receipt of complaints, the issuance of acknowledgments and notifications to the complainant, the creation of a complaint file, the transfer of this file to the Autorité des Marchés Financiers (hereinafter referred to as "the Authority"), and the compilation of complaints for the purpose of preparing and submitting a semi-annual report to the Authority.

 

Responsible Party

The firm’s manager, Sarah-Eve Couturier, is responsible for implementing the policy and acts as the main contact with the Authority. She ensures the training of staff and representatives, particularly by providing them with the information necessary to comply with this policy.

The person responsible is also tasked with the following:

• Sending an acknowledgment of receipt to the complainant.
• Issuing the necessary notices to the complainant.
• Transmitting the file to the Authority upon the complainant’s request.
• Maintaining a complaint log.
• Submitting a semi-annual report to the Authority.

 

Definition of a Complaint

For the purposes of this policy, a complaint is defined as the expression of at least one of the following:

1. A grievance against a registered representative.
2. Identification of actual or potential harm suffered or that may be suffered by a consumer.
3. A request for corrective action.

An informal attempt to resolve a specific issue does not constitute a complaint, as long as the issue is addressed within the regular activities of the registered representative and without the consumer formally lodging a complaint.

To be admissible, a complaint must be submitted in writing by the complainant.

 

Complaint Submission

Consumers wishing to file a complaint must do so in writing to the following address:

BRAVIA GESTION PATRIMOINE INC.
Sarah-Eve Couturier
141 Boulevard Saint-Luc #201, Saint-Jean-sur-Richelieu, QC, J2W 2G7
Phone: 514-462-4865
Email

Any individual who receives a complaint must forward it immediately to the policy's responsible party. If a representative receives a written complaint at their office, they must promptly forward it to the firm's manager without delay.

 

Acknowledgment of Receipt

The responsible party must acknowledge receipt of the complaint within five (5) business days of its receipt, informing the consumer that the case will be reviewed within 90 days.

The acknowledgment of receipt must include the following details:

• A description of the complaint, including the harm suffered or potential harm, the grievance against the representative, and the requested corrective action.
• The name and contact details of the complaint handler.
• For incomplete complaints, a notice requesting additional information, which the complainant must provide within 15 days, failing which the complaint will be considered abandoned.
• A copy of the complaint processing and dispute resolution policy.
• A notice informing the complainant of their right to request the transfer of their file to the Authority if dissatisfied with the outcome or the process after the 90-day period for receiving the final response has expired (but within one year of receiving the response).
• Information on mediation as an alternative dispute resolution option.
• A reminder that filing a complaint with the Authority does not interrupt the statute of limitations for civil court proceedings.

Creation of the Complaint File

A distinct file must be created for each complaint, which must include:

1. The complainant’s written complaint detailing the three elements: the grievance, the harm suffered or potential harm, and the requested corrective action.
2. The result of the complaint processing, including analysis and supporting documents.
3. A copy of the final written and reasoned response from the representative, sent to the complainant.

The complaint file will be kept at the firm’s business address.

 

Complaint Processing

Upon receipt of a complaint, the responsible party must investigate to determine the facts related to the allegations.

Complaints must be handled fairly and impartially, with an adequate response provided based on the specific situation.

Processing must occur within a reasonable time frame after all necessary information is received.

The responsible party must provide a final written and reasoned response to the complainant at the conclusion of the investigation.

 

Transfer of the File to the Authority

If the complainant is dissatisfied with the outcome or the process, they may request that the firm transfer their file to the Authority.

This request can only be made after the expiration of the timeline for receiving a final response, within one year of the date the response was received.

The transferred file will include all documentation related to the complaint.

 

Complaint Register and Reporting

The firm must maintain a complaint register, updated by the responsible party.

All written complaints and relevant judicial proceedings must be logged.

An annual report on complaints, including their nature and number, must be submitted to the Authority between March 1 and May 1 each year, covering the previous calendar year.

 

Representative Obligations

When a consumer verbally expresses a grievance, the representative must suggest that they submit a written complaint and provide the contact information of the responsible party.

If the representative receives a written complaint, they must forward it immediately to the firm’s manager.

Representatives are required to collaborate fully with the investigation, responding promptly to all requests for information or documents within 10 days.

Representatives must also immediately inform their professional liability insurer of any consumer complaint.

 

Sanctions

In case of disputes or disciplinary complaints, the firm may impose disciplinary measures on a representative, including termination of their contract. The sanction will be proportional to the misconduct, considering its severity.

 

Effective Date of the Policy: January 2025