Complaint Handling and Dispute Resolution Policy

Purpose of the Policy

The purpose of this Policy is to establish guidelines for complaint handling and dispute resolution. In particular, it outlines the procedures for receiving and managing complaints at Zamax Financial, as well as the transmission of such complaints and the preparation of reports for the Autorité des marchés financiers ("AMF").

Implementation of the Policy

Zamax Financial is responsible for implementing this Policy.

Zamax Financial serves as the designated contact with the AMF and, where applicable, ensures that its personnel receive appropriate training regarding complaint handling and dispute resolution. Zamax Financial ensures that this Policy is communicated to all personnel and that they have the necessary tools to implement it. Zamax Financial also ensures compliance with all applicable obligations.

Complaint

For the purposes of this Policy, a complaint includes the following elements:

  • A reproach or grievance made by a complainant against Zamax Financial;

  • The identification by a complainant of actual or potential harm suffered or that may be suffered by a consumer due to the actions or omissions of Zamax Financial;

  • A request by a complainant for corrective action or remediation.

Exclusions

The following does not constitute a complaint:

  • An informal request intended to correct a specific issue, provided the issue is addressed through Zamax Financial's regular business activities and the consumer has not formally expressed dissatisfaction.

If a communication from a consumer or complainant does not meet the above definition of a complaint, any steps taken by Zamax Financial to transfer the matter to the appropriate person or entity shall not be considered subject to this Policy. The same applies when Zamax Financial opens an internal file regarding such communication.

As Zamax Financial maintains business relationships with numerous industry participants, it may conduct internal or external investigations to determine whether it wishes to continue business relationships with parties who are the subject of a complaint or expression of dissatisfaction.

Administrative Procedures

Any communication from a consumer or complainant that meets the definition of a complaint outlined above must follow the process described herein.

Receipt of a Complaint

A complainant wishing to file a complaint is invited to do so in writing and address it to:

Compliance Director

Name: Alexanne Filion
Address: 638 9 Ave, Wainwright, AB T9W 1B3

Email: info@zamaxfinancial.com

Telephone: (819) 230-2209

If a complaint is received by an employee of Zamax Financial, that employee must forward it without delay to the Compliance Director for processing under this Policy.

If the complaint is made verbally, the individual receiving the complaint must prepare a written summary.

Upon receipt of a complaint, Zamax Financial shall ensure that an acknowledgment of receipt is sent to the complainant containing the following information:

  • A summary of the complaint, including the nature of the grievance, the alleged harm, and the corrective measures or remedies requested;

  • The name and contact information of Zamax Financial;

  • Any information required by Zamax Financial to properly investigate the complaint;

  • The deadline for providing missing information and notice that failure to provide such information may result in the complaint being deemed abandoned;

  • A copy of this Complaint Handling and Dispute Resolution Policy;

  • Notice informing the complainant of their right to request the transfer of their file to the AMF if they are dissatisfied with Zamax Financial's final position or the handling of their complaint;

  • Notice that the AMF may, where appropriate, provide dispute resolution services;

  • Notice that filing a complaint with Zamax Financial or the AMF does not suspend any limitation periods applicable to civil remedies available to the complainant or consumer.

Complaint File

Each complaint received by Zamax Financial shall be handled separately and maintained in an individual complaint file.

Upon receipt of a complaint, a file shall be opened containing:

  • A copy of the written complaint;

  • For verbal complaints, a copy of the written summary prepared by the recipient;

  • A complaint summary sheet outlining:

    • The grievance against Zamax Financial;

    • The alleged harm;

    • The requested corrective action or remedy;

  • The results of the complaint review process, supporting analysis, and relevant documentation;

  • The final written response provided to the consumer, including the reasons supporting the decision.

Complaint Handling Process

Within ten (10) days of receiving a complaint, Zamax Financial shall ensure that the acknowledgment of receipt described above is sent to the complainant.

Zamax Financial shall ensure that the complaint is reviewed and that a final response is provided no later than the later of:

  • Thirty (30) days following the acknowledgment of receipt; or

  • Thirty (30) days following receipt of any additional information requested in the acknowledgment.

Where a complaint raises complex issues or requires extensive review, the designated individual may provide a status update explaining the progress of the review and any additional time required rather than issuing a final response within the prescribed period.

Review Process

Upon receipt of a complaint, Zamax Financial may either:

  • Handle the complaint directly; or

  • Delegate the review to an employee.

This decision, and the name of the delegated employee if applicable, shall be recorded in the complaint file.

Whether handled directly or delegated, Zamax Financial must ensure that an acknowledgment of receipt is sent within the prescribed timeframe.

Analysis

The individual responsible for reviewing the complaint shall first determine whether the complaint requires substantial investigation.

If necessary, the complainant shall be informed of the estimated timeframe required and the status of the review. Such notices shall be documented in the complaint file and may be provided more than once depending on the complexity or seriousness of the matter.

The reviewer shall:

  • Examine the complaint;

  • Obtain, within a reasonable timeframe, the version of events from the individual who is the subject of the complaint;

  • Review relevant documents that are available or can reasonably be obtained;

  • Document the analysis and retain relevant records in the complaint file.

Once the review is complete, the reviewer shall formulate working conclusions.

These working conclusions do not form part of the complaint file.

Response

If the reviewer is not the designated individual, the reviewer shall provide their conclusions to the designated individual.

The designated individual shall review the conclusions and prepare the response.

The response must:

  • Be in writing;

  • Include the reasons supporting the decision;

  • Be retained in the complaint file.

If the response is final, it must clearly indicate:

  • The complainant's right to request that the file be transferred to the AMF if they remain dissatisfied with Zamax Financial's final position or the handling of the complaint; and

  • The procedure for requesting such a transfer.

If the response is not final, it must explain the steps the complainant may take to obtain a final response.

Transfer of a Complaint to the AMF

If a complainant wishes to exercise their right to have the complaint file transferred to the AMF, they must notify the Compliance Director.

Upon receipt of such a request, the designated individual shall transfer the complaint file to the AMF in accordance with AMF requirements.

Before transfer, the file shall be reviewed to remove:

  • Personal information that is not relevant to the handling of the complaint; and

  • Internal working conclusions or notes.

Policy Availability

The current version of this Policy may be consulted at any time on this website.