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Last modified: July 05, 2023 03:12 (UTC+08:00)

Complaints Handling Policy – DNBC Financial Canada Limited

1. Introduction

DNBC Financial Canada Limited (“the Company”) is a Money Service Business (MSB) incorporated and registered under the laws of Canada, with Incorporation number: BC1314756. The Company is authorized and regulated in Canada by the Financial Transactions and Reports Analysis Centre of Canada (hereinafter referred to as “FINTRAC”) and subject to FINTRAC rules, with MSB registration number: M21756795.

The Company shall establish, implement and maintain effective and transparent procedures for the reasonable and prompt handling of complaints or grievances received from retail or potential retail clients, and keep a record of each complaint or grievance and the measures taken for the complaint’s resolution.

2. Complaints

As part of our commitment to provide the best possible services to our Clients, we uphold effective and transparent procedures for prompt complaint handling for existing and potential Clients. We maintain Records of Complaints and measures taken for expedient complaint resolution, in line with applicable Laws, Rules and/or Regulations and we are pleased to operate in accordance with the Complaint Management Procedures of Financial Transactions and Reports Analysis Centre of Canada (“FINTRAC”).

We will attempt to deal with your Complaint promptly and efficiently. We will follow the procedures outlined below to ensure that your Complaint is resolved within a period of fifteen (15) business days (where possible). Some Complaints can be resolved more quickly depending on the facts and the nature of the Complaint. If the Complaint is more complex and takes longer than fifteen (15) business days to resolve, we will inform the reasons for the delay and when the Company’s Investigation is expected to be completed.

3. Types of Complaint Handled

In line with the foregoing, we will investigate a Complaint, if it is submitted to us or officially through FINTRAC, in accordance with the Complaint Handling Procedures described below.

Clients’ complaints or grievances are initially handled by the Back Office/Account Opening Department. However, the final settlement of non-trivial complaints or grievances needs to be approved by the Compliance Officer and if necessary by Senior Management.

4. How to make a Complaint

Your complaints should be submitted to the following electronic mail address [email protected].

Upon receipt of a Formal Client Complaint, our employee will contact you through the most convenient communication channel to acknowledge receipt of the complaint and provide an estimated timeframe for feedback, within two (2) working days from the date the Complaint was received.

5. Procedure to be followed when a formal complaint is received

The procedure which shall be followed by the Company’s Back Office/Account Opening Department, when handling clients’ complaints or grievances, is the following:

  • Upon the receiving Client Complaints Form from a member of the Back Office/Account Opening Department, the complaints should be registered in the Complaint’s Register. Once the complaint is recorded it shall never be deleted and hence the resolution of the issue needs to be followed through and documented
  • The following details are documented in the Complaint’s Register:

○ The date of receipt of the complaint

○ Client name and number of brokerage agreements.

○ The details of the identity of the customer who filed the complaint.

○ The service to which the complaint refers.

○ The employee is responsible for the provision of services to the Client.

○ The department to which the employee relates.

○ The details of the complaint – full description, including dates, figures, amounts, etc.

○ The extent in financial terms of the potential loss that the customer claims he/she has suffered or as it is derived from the content of the complaint.

○ A person who was determined as responsible for the review and resolution of complaints

○ Reference of any correspondence exchanged between the Company and the client.

○ Summary of the content of the reply of the company to the Client and description of taken actions.

○ The date of the Formal Response to the Client.

○ The status of the complaint.

  • The complaint in the form that has been received should be forwarded to the head of the department where the complaint is addressed within three working days.
  • The Head of the department where the complaint is addressed within two working days should investigate the complaints, determine the responsible person, indicate a timeframe required to resolve complaints and communicate this information to the Back Office/Account Opening Department for records. The complaints received are investigated fairly and possible conflicts of interest identified shall be mitigated.
  • The member of the Back Office/Account Opening Department within 5 business days from the date the Complaint was received, shall inform the client that the complaint or grievance has been

forwarded to the relevant department/personnel, providing all details so that the client is aware who is dealing with his/her complaint or grievance and indicate timeframe.

  • A person who was determined as responsible for the resolution of complaints within determined timeframe gathers and investigates the events leading to the complaint or grievance, all relevant evidence and information regarding the complaint.
  • All non-trivial complaints or grievances shall be brought to the attention of and their resolution should be approved by the Senior Management.
  • Upon completion of the investigation, a report shall be prepared stating the facts which lead to complaint, reasons for failure of procedure followed and the action to be taken to resolve complaints together with the Formal Response and brought to the Head of the department for review and approval.
  • In the case where a client complaint or grievance is valid, the Head of Department(s) to which the complaint or grievance is related shall take such necessary action to identify and verify:

○ Reasons for failure of the procedure followed.

○ Weaknesses of the internal controls.

○ Implementation of internal controls that would prevent any complaint or grievance in the future.

  • All suggested procedures shall be approved by Senior Management at the meeting following the completion of the investigation.
  • Within a determined timeframe communicated in the written Acknowledgement with the Client, the Back Office/Account Opening Department will send a Formal Response to the client.
  • However, if a complaint cannot be processed within a determined time frame, the Back Office/Account Opening Department will inform the client in writing that the investigation is continuing, the reasons for the delay, and when the Company expects to be able to contact the Client again
  • Once the issue has been resolved the Back Office/Account Opening Department documents the resolution of the complaint, and inputs a closed status for the complaint in the register, indicating a description of the actions taken.
  • Upon termination of the investigation, the Head of Back Office/Account Opening Department will notify the client in writing about the outcome of the complaint.

6. Record-keeping of complaints or grievances received

The Company shall maintain all complaints or grievances for a minimum period of five years. The responsible department shall be the Back Office/Account Opening Department.

7. Accountability to FINTRAC

The Company is required to provide to the Commission information regarding the complaints it receives. The said Document is submitted in an electronic form to the Commission on a basis period.