Complaint and Dispute Resolution Policy

Purpose:

The purpose of the Complaint and Dispute Resolution Policy is to establish an open and equitable procedure for dealing with complaints pertaining to the services we provide and our business practices. Complaints made in accordance with the procedures set out in this policy will be addressed in a prompt and efficient manner.

What is a complaint?

A complaint refers to the expression of one or more of the following:

• An assertion that Cowan Insurance Group, in connection with providing its products or services has:
  • Engaged in unfair business practices
  • Violated applicable regulation or law
  • Acted in an unethical manner
• A request for remedial action
• Identification of real or potential harm sustained

Steps taken to address a specific problem, or situation, are not considered a complaint provided the issue is resolved as part of normal business activities, and a complaint has not been filed. An example would be addressing a concern brought to the attention of the business through social media.

Addressing complaints

Complainants are encouraged to first contact their broker or appropriate relationship manager or service representative, who may be able to resolve the issue directly.

If the initial point of contact is unable to resolve the concern, complainants may request that the complaint be escalated to senior management of the business unit in a further attempt to resolve the issue.

Upon receiving the complaint, the business unit representative assigned to the complaint will:

• Contact the complainant to acknowledge receipt of the complaint within three business days of receiving the complaint.
• Create a file for the complaint containing the details of the complaint, the outcome of the complaint examination process with any applicable supporting documents, and all written correspondence to the complainant.
• Within ten business days of receipt of the complaint, prepare and send a written response to the complainant with justifying reasons for the outcome, or explain that more time is required and why.

Should the complainant be unhappy with the resolution of their file, they may contact the company Complaint Officer.

Complaints submitted to the Complaint Officer must be put in writing (letter, email, or fax) to:

Complaint Officer
Cowan Insurance Group

Mailing address:
705 Fountain Street North,
PO Box 1510, Cambridge, ON, CA, N1R 5T2

Courier address:
705 Fountain Street North,
Cambridge, ON, CA, N3H 4R7

Fax: (519) 650-6366
Email: ComplaintOfficer@cowangroup.ca

Complaint Officer

Cowan will appoint a Complaint Officer to act as the point person between the complainant and Cowan.

Responsibilities of the Complaint Officer:

After a written complaint has been received, the Complaint Officer initiates the following steps:

• Confirm receipt of the complaint via email to the complainant within five (5) business days, informing the complainant that steps are underway to resolve the matter
• Record the escalated complaint in the complaint file
• Contact the applicable department head or Senior Leadership Team (SLT) member based on the details of the complaint
• Establish a timeline with the department head or SLT member for next steps in the complaint resolution process
• Conduct follow-up with department head or SLT as required
• Communicate any actions taken to the complainant within ten (10) business days
  • Actions could include:
    • Disciplinary action taken such as employee retraining, suspension, or termination
    • Updates to policies or procedures
    • Clarification to complainant regarding concerns
    • No action required
  • If the issue cannot be resolved within ten (10) business days, contact the complainant explaining that more time is required
  • Update complaint log

Responsibilities of Department Head/SLT

• Conduct an investigation at the request of the Complaint Officer into the complaint and speak to any parties who may be involved
• If action is required, it will be communicated to the employee or stakeholder involved
• Inform Complaint Officer of any findings or actions

Handling Process:

1. Acknowledge receipt with complainant within one business day of receiving the complaint
2. Complaint will be recorded in the complaint file
3. Complaint must be acknowledged in writing with the complainant within five (5) business days. The acknowledgment will contain: a description of the complaint, name of complainant, name and contact information of person handling the complaint, the time frame required for the investigation (10 business days)
4. If the complainant is not satisfied with the outcome, the complainant may make a complaint in writing to the Complaint Officer
5. Complaint Officer will report the complaint to any applicable SLT members when appropriate
6. After completing the investigation, the Complaint Officer will prepare and send the complainant a final written response (within ten business days) addressing the complainants concern.
7. If the Complaint Officer is unable to complete the investigation within ten business days, with a written response will be sent to the complainant with an expectation of the amount of time required to complete the investigation
8. Provide information to the complainant regarding escalation to appropriate regulatory body as required