Objective of the Policy

Our firm, Asassur, must maintain a complaint register (below) in which we record all information related to complaints received.
The objective of this policy is to establish a transparent, fair, and free procedure for handling complaints, in compliance with the requirements of the Autorité des marchés financiers (AMF). This policy outlines our approach to the analysis, resolution of complaints, and the fulfillment of regulatory obligations, including reporting complaints to the AMF’s Complaint Reporting System.

Person Responsible for Complaint Handling

Mr. Yu Huang, President, is the person responsible for handling complaints and enforcing this policy within ASASSUR (“we,” “our,” “ours,” hereafter “ASASSUR”). Mr. Huang is also designated as the AMF representative.
The person responsible for complaints has the following duties:

• Acknowledge receipt of the complaint within a reasonable time frame (maximum 10 business days);
• Ensure that the complaint is analyzed and handled within the allotted time;
• Ensure that all complaints meeting AMF reporting criteria are reported to the AMF’s Complaint Reporting System within the required timeframe;
• Forward the complaint file to the AMF at the complainant’s request;
• Provide periodic reports to the AMF, including a list of complaints (if applicable), upon request.

Definition of a Complaint

A complaint is defined as a dissatisfaction expressed by a client that involves:

• A grievance against ASASSUR or one of its representatives;
• The identification of a real or potential harm suffered or to be suffered by the complainant;
• A request for corrective action or compensation.

Dissatisfaction or Concerns

If a client encounters an issue or has a question, an informal attempt to resolve the issue or obtain information is not considered a complaint. However, such follow-up is encouraged and should be carried out through our regular customer service procedures.

Step 1: Informal Resolution Attempt

The client is first invited to contact their representative or customer service to attempt an informal resolution of the incident. They can do so by phone at 514-748-7165 ext. 101 or by email at info@asassur.com.

Step 2: Submit the Complaint to the Complaints Handler

If the client remains dissatisfied with the solution proposed in the previous step, they may submit an official complaint, by phone, email, or in writing, to the complaints handler:
ASASSUR
3055 Saint-Martin O, Suite 500
Laval (Quebec) H7T 0J3
Tel: 514-748-7165 Ext#101
Fax: 514-221-4698
Email: info@asassur.com
The complaints handler must acknowledge receipt of the complaint within a maximum of 10 business days.

Step 3: Analysis and Handling of the Complaint

ASASSUR must analyze and handle the complaint within a reasonable timeframe (maximum of 30 business days following the receipt of all necessary information). If this deadline cannot be met, a written notice will be sent to the complainant explaining the delay and providing a new estimated timeline.
The response to the complaint must be sent in writing, including a clear and reasoned explanation of the decision made.
Reporting to the AMF’s Complaint Reporting System:
Any complaint that meets the AMF reporting criteria must be reported within the required timeframe to the AMF’s Complaint Reporting System via the AMF’s official platform. These complaints must always be reported to the AMF using the Online Services (SEL) section under Complaint Reporting, between March 1 and May 1 each year.
The reported information includes: the nature of the complaint, actions taken, and proposed or applied corrective measures.

Step 4: Response and Resolution

After reviewing the complaint, ASASSUR will provide the complainant with a formal written response, which must specify:

• The conclusion of the analysis;
• Actions taken, if any;
• If the complaint is found to be valid, the corrective measures taken or proposed.
  The processing time is a maximum of 30 days from the receipt of all necessary elements for a complete review of the complaint.

Transmission of the File to the Autorité des marchés financiers (AMF)

If the complainant is dissatisfied with the response or handling of their complaint, they may request that their file be transferred to the AMF for further evaluation. This transfer must be done upon the complainant’s request, and the complete file, including all relevant documents, must be included.
The complainant must be informed of this option throughout the process.

Complaint File and Follow-up

A separate file is created for each complaint, which includes:

• The initial complaint;
• All documents and correspondence related to the complaint;
• Follow-up on actions taken;
• The final, reasoned response sent to the complainant.
  This file must be kept secure and confidential, in compliance with applicable regulations.

Reports and Reporting to the AMF’s Complaint Reporting System

ASASSUR must report all complaints that meet the criteria in the AMF’s Complaint Reporting System in accordance with the prescribed timelines.
Additionally, a semi-annual report describing the number and nature of complaints must be submitted to the AMF via the appropriate secure channels (either via a secure link or through the official AMF online platform).

Complaint Reports to the AMF

In compliance with AMF requirements, ASASSUR submits a semi-annual report detailing the number and nature of complaints received (if applicable). This report must be securely submitted to the AMF, either through a secure link or via the official AMF platform.

Effective Date

This policy is effective as of November 15, 2024.

Important Notes for AMF Compliance:

• Complaint Acknowledgment: The AMF requires that acknowledgment of receipt be sent within 10 business days.
• Processing Time: The AMF mandates a maximum processing time of 30 days to respond to complaints, unless a delay is justified.
• Reporting to AMF’s Complaint Reporting System: Complaints must be reported according to AMF requirements via the official platform.
• Transparency: Clear follow-up and regular reports must be provided to the AMF, including semi-annual reports.
• Complete File: The file for each complaint must be maintained in full, and information must be easily accessible to the AMF upon request.