The purpose of this complaint examination and dispute resolution policy is to comply with the regulations of the general insurance industry, to meet the public’s expectations in terms of complaint examination and to set up a free and equitable procedure for examining complaints received by BFL CANADA (hereinafter referred to as “BFL”). It is intended in particular to govern:

• The receipt of complaints;
• The delivery of the acknowledgement of receipt and notices to the complainant;
• The creation of the complaint file, and
• The transfer of the complaint file to the proper government councils, the General Insurance OmbudService (GIO) (www.giocanada.org) or the OmbudService for Life and Health Insurance (OLHI) (www.olhi.ca), as applicable.

Person in Charge

The Person in Charge of the application of the policy for all provinces except Québec is Connie Tambasco.

The Persons in Charge for Québec are Daniel Binette (on behalf of BFL CANADA Risk and Insurance Inc.) and David Vanasse (on behalf of BFL CANADA Consulting Services Inc.). They act as the respondents with the AMF and the complainant.

The Person in Charge shall also:

• Send an acknowledgement of receipt to the complainant;
• Send the required notices to the complainant;
• Send the file to the proper governing councils (AMF for Quebec), the GIO or the OLHI, at the complainant’s request;
• Maintain a complaints register;
• File reports with the proper governing councils as applicable.

Definition of a Complaint

For the purposes of the policy, a complaint exists when the dissatisfaction of a client persists even after the problem has been addressed in the course of normal business and the dissatisfaction is expressed by any one of these three circumstances:

• A reproach against BFL CANADA;
• The identification of a real or potential harm that a consumer has experienced or may experience;
• A request for remedial action.

An informal step aimed at correcting a particular problem is not a complaint, insofar as the problem is dealt with as part of BFL CANADA’s regular activities and without the consumer having filed a complaint.
To be admissible, a complaint must be made in writing by the complainant.

Receipt of the Complaint

A consumer who wishes to file a complaint shall do so in writing at the following address:

Quebec

BFL CANADA Risk and Insurance Inc.
Att: Mr. Daniel Binette
2001 McGill College Ave., Suite 2200
Montreal, Quebec H3A 1G1
Telephone: 514-843-3632
Fax: 514-843-3842

BFL CANADA Consulting Services Inc.
Att: Mr. David Vanasse
3448 Stanley St,
Montreal, Quebec H3A 1R8
Telephone: 514-843-3632
Fax: 514-843-3842

Canada, except Quebec:

BFL CANADA

Att: Ms. Connie Tambasco
2001 McGill College Ave., Suite 2200
Montreal, Quebec H3A 1G1
Telephone: 514-843-3632
Fax: 514-843-3842

The person in charge of the application of the policy shall acknowledge receipt of the complaint within five (5) business days.

The acknowledgement of receipt shall contain at least the following information:

• A description of the complaint received specifying the actual or potential harm, the reproach against BFL CANADA and the request for remedial action;
• The name and contact information of the person in charge of examining the complaint;
• In the case of an incomplete complaint, a notice requesting additional information to which the complainant is asked to respond within 30 days, failing which, the complaint will be considered to have been dropped;
• A copy of BFL CANADA’s Complaint Examination and Dispute Resolution Policy;
• A notice informing the complainant of his right to request the transfer of his file to the appropriate governing council (the AMF in Quebec), the GIO or the OLHI, if he is dissatisfied with the outcome of the examination of his complaint or the examination itself. The notice shall also indicate that the governing council may offer mediation if it deems it appropriate and the parties agree;
• A notice reminding the complainant that mediation is an amicable settlement process in which a third party (the mediator) intercedes with the parties to assist them in reaching a satisfactory agreement;
• A notice informing the complainant that the filing of a complaint with the appropriate governing council, the AMF, the GIO or the OLHI does not interrupt the statute of limitation relating to his recourses against BFL CANADA before civil courts.

Creation of the Complaint File

A separate file shall be created for each complaint.

The file shall contain the following:

• The complainant’s written complaint, including the element or elements of the complaint;
• The acknowledgement of receipt including the notice;
• The outcome of the complaint examination process (the analysis and the supporting documents);
• All related correspondence;
• A copy of BFL CANADA’s final written answer, containing reasons for the answer, as sent to the complainant.

Complaint Examination

Upon receipt of a complaint, BFL CANADA shall conduct an investigation. The complaint shall be examined within a reasonable time period, namely within 30 days following receipt of all the information required for its examination.

After the investigation, the person in charge shall send the complainant a final answer in writing, providing the explanation of BFL CANADA’s decision.

Transfer of the File to the Appropriate Governing Councils, the AMF, the GIO or the OLHI

If the complainant is not satisfied with the result of the examination of his complaint or with the examination itself, he may ask BFL CANADA to transfer his file to their provincial insurance governing council (AMF in Quebec), to the GIO or to the OLHI.

The transferred file consists of all documents relating to the complaint.

Compliance with the rules governing the protection of personal information remains the responsibility of BFL CANADA.

Creation and Maintenance of a Register

A complaints register shall be established for purposes of the application of the policy. The person in charge shall be responsible for keeping the register up to date.

Any complaint that falls within the definition of this term shall be recorded in the register, in particular:

• Any written complaint, regardless of the level of intervention involved in the examination of the complaint;
• Any legal proceeding contemplated in the definition of the word complaint.

Effective Date

This policy is effective beginning January 1, 2005.