Purpose of the policy

The complaint handling and dispute resolution policy allows customers of ASASSUR, Damage Insurance Firm to ensure that any complaint received is analyzed and responded to in a fair and free process in accordance with the Regulation respecting the handling of complaints and the resolution of disputes in the financial sector.

ASASSUR is committed to ensuring that every member of staff is informed and knows how to assist and refer a customer who expresses dissatisfaction or makes a complaint.

What is a complaint?

Regulatory changes have established a new definition of a complaint and its characteristics. When a client’s action meets the definition of a complaint, the firm and its resources will be required to report it to the firm’s complaints officer.

A complaint expresses:

• A criticism or dissatisfaction with our services or a product we offer
• The complaint is made by a person concerned about whom the firm has a file
• An expectation on the part of the client that our firm will take action to remedy the situation.

Example:

The customer criticizes their representative for not clearly explaining the fees that their company charges them for services rendered and requests that these fees be canceled.

Complaints Policy and Dispute Resolution Officer

Within ASASSUR, XXX-complaints-manager-XXX is appointed as the person responsible for the fair handling of complaints we receive and has the skills to perform this role.

The complaints officer may also appoint a person to act under his or her supervision.

This fairness is evident in the objectivity of our analysis, but also in the standardization of our tools and documents associated with complaint handling.

Our manager also ensures that:

1. Ensure that our customers can easily obtain support or up-to-date information on how we handle complaints;
2. Upon hiring a new employee, provide them with access to the firm’s Policy and Procedures GUIDEl containing the complaint handling policy;
3. Train staff to ensure compliance with this policy;
4. Supervise staff in monitoring and applying this procedure.
5. Ensure that complaints are handled objectively, diligently, and fairly, taking into account the interests of the client.
6. Acknowledge receipt of complaints from complainants.
7. Send the required notices to complainants.
8. Ensure that the established process and deadlines are respected;
9. Forward complaint files to the AMF at the request of complainants;
10. Maintain an up-to-date complaint register;
11. Submit an annual complaint report to the AMF within the prescribed time limits via the online service (SEL).
12. Monitor legal changes affecting the handling of complaints.

Methodology for handling complaints and resolving disputes

In order to structure our complaint files. ASASSUR has established a structure to ensure the documentation and supervision of complaint handling and dispute resolution.

This structure allows us to:

• Process complaints and monitor dispute management
• Reconcile complaints in a separate file from the one in which regular operations are carried out,
• Follow the procedure for handling complaints set out in this GUIDE

• Standardize our documents

Complaints register

Our register contains all complaints that meet the definition of a complaint, regardless of the level of intervention required to handle the complaint.

We ensure that our register is kept up to date.

It may happen that a complaint is not recorded in our register on the day it is received (e.g., if it is received outside of business hours, on holidays, etc.).

We record information in the register that allows our managers to be informed of the complaints we receive and the follow-up we do.

Our sound complaint management

Taking action on a complaint

Each of the resources at ASASSUR is committed to helping every customer understand our complaint process by guiding them through each step, providing them with information, and answering their questions.

• When the complaint concerns another party

During the analysis of the complaint, if we find that the complaint concerns another party, we will:

• Inform the customer;
• Explain to them how the complaint relates to that party;
• Provide them with contact information if we have it;
• Invite them to also file their complaint with the other intermediary or insurer (without withdrawing it from our firm).

• When the complaint may affect other clients

If, during the analysis of a client’s complaint, we find that the issues raised may have repercussions for other clients, we:

• Take the measures at our disposal to correct the situation for all of our clients.

Who handles a complaint according to predetermined criteria

When handled by the person responsible for handling complaints or by a person acting under their supervision, that person will provide the client with a final written response within the time frame set out in our policy.

Some complaints may be handled by another person, such as one of our representatives or our administrative staff. This person can process the complaint in accordance with our simplified process. If the complaint cannot be resolved to the customer’s satisfaction through this process, the complaint handler or someone under their supervision will take over to finalize the process and provide a final written response to the customer.

We take certain factors into account when determining who will handle the complaint, including:

• the complexity of the complaint;
• the skills of the person who will handle the complaint, including their knowledge, training, and professional experience;
• the workload of the person who will handle the complaint.

In all cases, we ensure that this person handles each complaint in accordance with our complaint handling policy and that they have access to all the information necessary to handle it.

Continuous improvement

Management closely monitors complaint handling in order to:

• Identify recurring issues that may be highlighted.
• Better understand the concerns expressed by our customers;
• Validate the number of complaints received and processed, as well as our responses to these complaints;
• Validate the common causes of complaints handled and the problematic situations that are thus revealed;
• Validate difficulties related to the implementation, dissemination, and enforcement of the policy;
• Take action if common causes emerge from the findings in our complaint log.

PROCEDURE – STEPS IN THE COMPLAINT HANDLING AND DISPUTE RESOLUTION PROCESS[3]   

STEPS IN THE COMPLAINT PROCESS (REGULAR PROCESS)

The following steps outline the application of the complaint handling policy and form an integral part of it.

ASASSUR handles each complaint objectively, taking into account the interests of the customer who made it, and we communicate with them in clear and simple language so that they can fully understand the process and its purpose.

Making a complaint (customer support)

Our customers can contact us at any time to obtain information on how we handle complaints, to file a complaint, or to inquire about the status of their complaint.

We are obligated to assist customers in filing and formalizing their complaints, as well as throughout the entire process.

Our customers can file a complaint in the manner that suits them best, either verbally or in writing:

By mail or in person:

ASASSUR

Attn: Complaints Manager: Ke Mo Huang

3055 Saint-Martin O, Suite 500,

Laval, Quebec

H7T 0J3

Our office hours:

Monday to Friday:                [9:00 a.m. – 17:00 p.m.]

Saturday and Sunday:         [Closed]

Email:

@: info@asassur.com

By phone or in person:

Office phone:           514-748-716

Fax line:                     514-221-4698

Authority complaint form:

Fill out the online complaint form[4] of the Autorité des marchés financiers (the “Authority”) and we remain available to assist you.

Here is the information that can be provided to the customer.

DOWNLOAD HERE:             Complaint Form

1. Complaints received by: a member of staff, Complaints Manager, or online
   • When a customer expresses a complaint or dissatisfaction, we determine whether or not it constitutes a complaint.

• We take into account all the information provided by the customer to assess whether their request constitutes a complaint.
  • If we are unsure, we contact them to discuss the situation in more detail and assess whether they are making a complaint.
• We are responsible for helping the customer to formulate their complaint properly,
  • for example by asking questions to understand the situation.
• We also make sure we understand their expectations of us in order to determine whether they are requesting:
  • a correction, a refund, an apology, etc.

• We take charge of the complaint.

• Once the complaint has been received by a member of staff, it MUST be submitted UPON RECEIPT and WITHOUT DELAY to our complaints manager.
• Our complaints manager:
  • Opens a complaint file (separate from day-to-day business)
  • Open a complaint form in a separate internal folder to follow the procedure (PERSO SI QFORMIT) or other customer means
  • Reconcile the complaint with the firm’s complaint register
• A member of our customer service department: Depending on your responsibilities within our firm, certain complaints may be handled by designated staff via the SIMPLIFIED PROCESS (description below)
  • Complaint handled during a phone call
  • Complaint handled within twenty (20) days
  • Follow-up must be sent to the manager to close the complaint in the register.

• Our complaints manager acknowledges receipt of the complaint

• Within 10 days of the date the complaint is submitted, an acknowledgment of receipt including the notice must be sent to the client.
  • APPENDIX N: Acknowledgment of receipt including the notice
    • Hyperlink to the firm’s privacy and personal information protection policy.
  • Copy of your complaint
  • Copy of our complaint handling and dispute resolution policy.
• PLEASE NOTE: In the case of an incomplete complaint, the notice will include a request for additional information, to which the complainant must respond within ten (10) days, failing which the complaint may be dismissed.
  • Complaint file documentation
• Our complaints manager ensures that the complaint file:
  • Is kept up to date
  • Contains the relevant documents and information as the complaint is processed.
    • If necessary, the complaints manager may contact staff to obtain any additional information that may be required.
  • The file is kept in accordance with the standards set out in our privacy and personal information protection policy.

2. Complaint analysis

• The complaints officer will analyze the complaint in order to:
  • Understand the customer’s complaint
  • Understand the customer’s expectations of ASASSUR.
• If necessary, the complaints manager may contact the customer to obtain any additional information required.
  • If additional information is documented, send a new copy of the complete complaint to the customer.
• If necessary, the manager will involve the lawyer responsible for professional liability.
  • APPENDIX N: Letter forwarding the complaint to professional liability

3. Final written response

Within 60 days* of the date the complaint was forwarded, a final written response must be sent to the client.

• Final written response letter with explanation

• APPENDIX N: Final decision letter
• The letter must explain:
  • How your complaint was analyzed;
  • The considerations leading to our response;
  • And, if possible, the proposed solution to resolve your complaint.
  • *Additional extension (CUSTOMER NOTICE)
• If the processing of your complaint is more complex or requires a longer period of time, the person responsible for complaints at ASASSUR must:
  • Notify the customer in writing, specifying the reasons for the additional delay of up to 30 days.
  • APPENDIX N: Letter notifying the customer of an extension of the complaint processing period

• We can provide three types of responses:

1. Grant the customer’s request: we can correct a situation, offer a refund or apology, etc.;
2. Propose a solution that partially meets the customer’s request or is different from their request: we try to find common ground;
3. Reject the customer’s complaint: if, after analysis, we conclude that the complaint is unfounded or that no settlement is possible.

• Evaluation of the offer and resolution of the complaint

ASASSUR gives the customer 30 days to evaluate and send their response to our complaints manager.

However, ASASSUR must have received feedback or a response from the customer within 30 days, unless the customer has requested a reasonable extension of time in order to obtain advice to make an informed decision.

ASASSUR will then expect one of the following responses:

• Acceptance of ASASSUR’s offer;

• Once an agreement has been reached with the customer, the agreed payment must be made by ASASSUR within thirty (30) days;
  • Refusal of the offer from ASASSUR;
    • If, however, the client remains dissatisfied with the way we have handled their complaint or with the response we have provided, they may request that we transfer their file (including all supporting documents) to the Autorité des marchés financiers
    • They may also contact the AMF directly.
    • In all cases, we will ensure that the file is forwarded to the AMF within a maximum of fifteen (15) days of receiving the request.
    • APPENDIX N: Complaint transfer form to the AMF (UPON CUSTOMER REQUEST)
  • Submission of a counteroffer*.
    • *APPENDIX N: Final decision letter / Customer counteroffer form.

If ASASSUR does not receive any further responses or follow-ups from the customer within the established complaint handling process deadlines, the complaint manager may be forced to close the complaint file.

• Before closing the file, it is recommended that an attempt be made to contact the customer and document the complaint file before closing it.

• Review of the complaint file by the AMF

At any time, a customer who remains dissatisfied with the way we have handled their complaint or with the response we have provided may contact the Authority and submit a transfer request directly to it. The customer may also request that we assist them with their transfer request.

DOWNLOAD HERE: FORM FOR TRANSFERRING A CASE TO THE AUTHORITY

ASASSUR will forward the complaint file to the Authority within a maximum of fifteen (15) days of receiving the request.

The Authority will review the file received and, if necessary, may request additional information or documents. Following its review of the file, the Authority will offer dispute resolution services, if it deems it appropriate.

SIMPLIFIED COMPLAINT PROCESS (for certain complaints)  

Depending on your responsibilities within our firm, certain complaints may be handled by designated staff through the SIMPLIFIED PROCESS.

COMPLAINT RESOLUTION – Simplified Process

We may handle and resolve certain complaints through a simplified process if we are able to offer:

• A satisfactory solution (solution or explanation accepted to resolve the complaint)
• A settlement within 20 days.
• Handling by a member of our customer service department supervised by the complaints manager (e., during a phone call).

NON-RESOLUTION OF COMPLAINT – Simplified process

If we are unable to propose a solution or provide explanations that resolve a customer’s complaint under this simplified process, the following steps must be taken:

• Notify the customer in writing before the 20-day deadline expires.
• Continue with the steps for handling a complaint. (Regular process)
  • The time taken to attempt to resolve the complaint through the simplified process does not affect our obligation to provide you with our final written response within the required time frame of sixty (60) days following the filing of the complaint.
  • All information, documents, and notes must be sent to the complaints manager to compile the complaint file.
• The complaints officer is responsible for the further processing of the complaint.
• Ensure that the complaint is entered in the complaint register.

Prepare and submit the complaint report to the Authority. [5]

Annually, ASASSUR will send its register to the Authority. The declaration is standardized for the entire industry. This declaration must be made according to the following instructions:

• A single annual submission of the declaration via the Authority’s online services (SEL) (companies) in the section called “Complaints Report.”

   COMPLAINT REPORT AMF E-Services