Complaint Policy

1. CLIENT COMPLAINT POLICY

(See below for information specific to clients residing or insuring property and/or assets in the province of Quebec)

Effective July 1, 2025

2. Purpose of the Policy

The purpose of the policy is to ensure complaints are processed fairly and resolved in a timely. Specifically, it provides a framework for the following:

Receiving and examining complaints
Sending acknowledgments of receipt and notices to complainants
Creating complaint records
Resolving complaints

Complaints received will be analyzed in a reasonable time frame, with responses and/or offers provided to the complainant to resolve the issue. All staff are expected to be familiar with and adhere to the policy.

For our Quebec clients, this includes sending records to the Autorité des Marchés Financiers (AMF) at the request of complainants and submitting complaint reports to the AMF.

We want to ensure we work through challenges with our clients should they arise.

3. Complaints Officer

Our complaints officer makes sure the complaints we receive are processed fairly and our policy is complied with and implemented across our firm so that, among other things,

Our management and staff understand and apply our complaint processing policy;
Our clients can readily obtain information on how we deal with complaints and the processing of their complaints;
Our staff complete the necessary follow-up to ensure our clients’ complaints are processed properly;
The people tasked with processing complaints have the necessary competence to process the complaints assigned to them; and
Each complaint is treated objectively and processed in a manner that considers the client’s interests.

For our Quebec clients, this includes sending records to the Autorité des Marchés Financiers (AMF) at the request of complainants and submitting complaint reports to the AMF.

4. Definition of a Complaint

A complaint is any verbal or written expression of a client’s reproach or dissatisfaction about the services or products we offer and the client’s expectation that we take action to address the complaint. This includes when a client expects compensation or an apology from us or requests that we take steps to address or put a stop to the situation giving rise to the complaint.

The following are not considered complaints:

A request for information or materials in respect of a product offered or service
A claim for an indemnity or an insurance claim
A request for correction of a clerical error or mistake in calculation, such as an error in transcribing information or mistake in calculating an amount owed (unless the error or mistake has further consequences for the client or one or more other clients, i.e. if the error results in costs that must be refunded to the client)
A request for access or amendment of personal information
Comments or feedback about our firm

Where a customer makes a complaint by phone or in person, the person taking charge of the complaint must document it so that it can be kept on file as a record of the complaint.

The initial expression of dissatisfaction by a customer, whether in writing or otherwise, will not be considered a complaint where the issue is settled in the ordinary course of business. However, where a client remains dissatisfied and the complaints officer takes charge of the dissatisfaction, then it is considered a formal complaint.

5. HOW TO SUBMIT A COMPLAINT

If you have any concerns, you are encouraged to first contact your broker or agent (if applicable), who can provide you with professional advice. Your broker or agent works for you, can advocate on your behalf and may be able to resolve your concerns or, if necessary, escalate your concerns to a member of management for their attention and further efforts for resolution. In some instances, your complaint may need to be redirected to your insurance company and their complaints officer.

If, for any reason, you feel that your concerns were not resolved, your complaint will be handled by the complaints officer.

Customers who wish to file a complaint can do so by phone, email or in writing to the following address:

Attention: Complaints Officer
CHES Special Risks Inc.
100 King Street West, Suite 5140
Toronto ON M5X 1E1

To help us process your complaint efficiently, please include:

Name
Address
Phone number
Email address
Insurance policy number (if applicable)
A description of your complaint
Relevant dates, documents, or communications
The outcome you are seeking

Clients can also submit their complaint by email below:

Email Us

Our Quebec clients can submit complaints using the AMF Complaint Form.

6. Support for Vulnerable Consumers

A vulnerable consumer is someone who, due to their personal circumstances, is especially susceptible to detriment when dealing with a business or organization that does not exercise the appropriate level of care in interacting with the consumer. Risk factors that contribute to consumer vulnerability include but are not limited to the following: illness, physical or cognitive disabilities, hearing or vision impairments, mental health issues, financial hardship, language barriers, cognitive or physical impairments connected with advanced aging, inexperience due to younger age and bereavement.

When dealing with a vulnerable customer, we will provide additional support as requested by the consumer which may include ensuring the customer is comfortable with the method of communication, treating the consumer with patience and empathy, asking the consumer if they understand or whether they need additional information, etc. In situations where it appears that a vulnerable customer is not competent to make a decision for themselves, we will attempt to identify whether another person, such as a caregiver or next of kin, is authorized to act on the consumer’s behalf.

For additional information, please review our Accessibility Statement.

7. Receipt of the Complaint

We are committed to process every complaint in a fair and impartial manner. We will

Investigate complaints competently, diligently and impartially.
Obtain additional information as necessary.
Assess fairly, consistently and promptly the subject matter of the complaint, whether the complaint should be upheld and whether remedial action may be appropriate.

In addition, we will ensure that all employees that may receive complaints related to any operations are trained in complaint identification to a level appropriate to their position and role with the organization and are aware of the above procedure.

In some instances, it may be appropriate for a client to escalate a complaint to their insurance company. Please visit your insurance company website for information regarding the respective insurance company complaint process and ombudsperson. The name of your insurance company can be found on your policy documents.

If you have a concern specifically about our Client Complaint Policy, you may contact the Financial Consumer Agency of Canada. Please note that the Financial Consumer Agency of Canada does not provide redress or compensation and does not become involved in individual disputes.

You may reach the Financial Consumer Agency of Canada at:

Financial Consumer Agency of Canada

6th Floor, Enterprise Building
427 Laurier Ave. West
Ottawa, ON K1R 1B9
English: 1-866-461-3222
French: 1-866-461-2232
Fax: 1-866-814-2224 / 613-941-1436

Additional Information for Quebec Clients

1. Receipt of the Complaint

On receipt of the complaint, the complaints officer will initiate the complaint examination process and send an acknowledgement of receipt to the complainant within 10 days.

The acknowledgement of receipt will contain:

A statement of the complainant's right to request to have the complaint record examined by AMF;
The complaint record identification code;
The date on which the complaint was received, if it is different than the date on which the complaint was registered;
The means by which the complainant may obtain information on the status of the complaint, including contacting the person assigned to process it, such as a business leader or complaints officer;
The expected timeframe for processing the complaint and the date by which we must provide a final response; and
A hyperlink providing access to the summary of the complaint processing and dispute resolution policy or a copy thereof.

2. The Complaint Examination

We are committed to process every complaint in a fair and impartial manner. We will investigate complaints competently, diligently and impartially; obtaining additional information as necessary and must assess fairly, consistently and promptly the subject matter of the complaint, whether the complaint should be upheld and whether remedial action may be appropriate.

We strive to examine every complaint within 30 days of receiving all the information necessary for the examination. A written final response must be provided to the complainant within 60 days following the receipt of the complaint.

If there are any extenuating circumstances during the examination process resulting in a delay in sending the final response to the complaint, the complaints officer will send the complainant a written notice.

The written notice will include:

An explanation of the circumstances causing the delay;
The date by which the final response will be sent to the complainant;
A statement of the complainant's right to request to have the complaint record examined by the AMF; and
The business contact information for the complaints officer.

After examining the complaint, the complaints officer will send the complainant a final response with justifying reasons. In most cases, the final response will be sent within 60 days following receipt of the complaint. At no time will the final notice be sent any later than 90 days following receipt of the complaint.

The final response to the complainant will include:

A statement to the effect that it is a final response;
A summary of the complaint received;
The conclusion of the analysis, including the reasons for the conclusion and the outcome of the complaint;
Details about the proposed solution to resolve the complaint or the reasons why no solution is being proposed;
If an offer to resolve the complaint is presented to the complainant, the time period within which the complainant may accept the offer;
A statement of the complainant's right to request to have the complaint record examined by AMF; and
The business contact information and signature of the complaints officer.

The complainant may continue to send new information after receipt of the final response, which we will examine accordingly.

3. Simplified Process for Certain Complaints

We may follow a simplified process for certain complaints. This process is used for complaints that we can resolve within 20 days.

We consider a complaint to be resolved to the satisfaction of the client when the client accepts our proposed solution to their complaint or when the explanations we provide are sufficient to resolve the complaint.

Under the simplified process, complaints may be referred to a member of our client service team. In addition, a written acknowledgment of receipt or written final response does not have to be sent to the client. The individual managing the complaint has the ability to process it verbally, such as during a phone call.

The individual who processes the complaint must, for each complaint:

within 10 days of receiving a complaint, inform the client that their complaint has been received and that they have the right to request to have their complaint record transferred to the AMF; and
within 20 days, provide the client with our response and the proposed solution to their complaint.

These exchanges may be summarized in a document placed in the complaint record or may be recorded in full in the complaint record. The complaint record, including the information used in processing and resolving the complaint, may be kept in the client record.

If we determine that a complaint cannot be resolved to the client's satisfaction within 20 days, the client is informed of this by way of a written notice sent before the end of the 20-day period. Any complaint that cannot be resolved using the simplified complaints process are assigned to the complaints officer.

4. Creation of the Complaint File

We create and maintain a separate record for each complaint, which includes all documentation relating to the complaint. The complaint record is kept for the same retention period as the client record and your complaint will be handled in accordance with our privacy policy. If the complaint is also directed at other financial institutions, such as the insurance carrier, they may need to be advised of the complaint. This record will be the one sent to the AMF at the complainant's request.

The complaint record must contain any documents and information that were used to analyze the complaint, including:

The complaint, including any conversations and correspondence with the client regarding the complaint, including emails, phone recordings, conversation summaries;
Any documents or information used in analyzing the complaint, including any exchanges with the complainant;
A copy of the acknowledgement of receipt sent to the complainant;
A copy of the final response provided to the complainant.

If necessary, the complaint record must also include:

Any conversations or correspondence with the client after the final response was issued (e.g., the client's questions and business's answers relating to the complaint, any new facts provided by the client and follow-up with the client);
The client's response to the business's offer to resolve the complaint and any follow-up on the offer;
The notice informing the client that their complaint will take more time to process than expected;
The information provided to the client if the business determines that the complaint involves another business.

5. Transferring a Complaint Record to the AMF

A complainant who is not satisfied with the business's final position or the way the complaint has been handled may request that we transfer the record to the AMF.

The complainant may make the request using the Form to Request the Transfer of a File to the AMF.

We must, within 15 days following the receipt of a request from the complainant, transfer the complaint record to the AMF and provide the name and business contact information for the complaints officer.

The AMF will examine the record and, if necessary, ask for more information or documents.

After examining the record, the AMF will, if it deems it appropriate, offer its dispute resolution services.

6. Complaint Reporting Obligation

The complaints officer must create and maintain a register of all complaints received. This register can facilitate the submission of the complaint report to the AMF.

During the annual reporting period (March 1 to May 1), we must report all complaints received between January 1 and December 31 of the previous year.

Periodic reports covering the following items will be made available to our officers:

The number of complaints received and processed and common causes thereof;
The outcome of the complaints;
Issues related to the implementation and dissemination of, and compliance with, the policy; and
Issues identified when ascertaining the common causes of processed complaints.

7. Additional Responsibilities

Training

We will ensure that all members of staff who may receive complaints from a Quebec client are trained in complaint identification to a level appropriate to their position and role with the organization and are aware of the above procedure. Completion of this training will be tracked.

Complaint Reporting

On a semi-annual basis, the complaints officer will report a summary of the complaints received to the officers of the company, including the causes and outcomes of the complaints, and the status of the employee complaint training.

Complaint Analysis

On an annual basis, the complaints officer will complete a review of the complaint records to develop a comprehensive view of the complaints received. This review process will focus on identifying any trends or issues that could be resolved by changes or improvements in our processes and procedures to prevent the recurrence of similar complaints.

8.Documentation and Tools

For further information, please refer to the following:

We are committed to the objective and fair review of complaints with a focus on positive customer outcomes. In a dynamic world, it is critical to honour the trust clients place in us.

We are dedicated to supporting you in meeting your clients' insurance needs.

Toronto

130 King Street West, 19th Floor, Toronto, Ontario, M5X 1E3

Ottawa

Vancouver

Montreal

3135 Boulevard Möise-Vincent, Suite 207 Saint-Hubert, Quebec, J3Z 0G7

Quebec City

Edmonton

*For informational purposes only. This document does not modify, extend, or alter the scope of insurance coverage. Please refer to any applicable insurance policy for the relevant terms, conditions, limitations, and exclusions. Insurance services are provided by CHES Special Risks Inc., operating as CHES Special Risk and/or CHES Solutions Spécialisées, an affiliate of Totalis Programs Underwriters. CHES Special Risk and CHES Solutions Spécialisées are registered trade names used by CHES Special Risks Inc. in the Canadian provinces and territories where their use is authorized and registered. CHES Special Risks Inc. does not provide legal or tax advice.