Summary of Altium’s Complaint Processing and Dispute Resolution Policy

Summary of Altium’s Complaint Processing and Dispute Resolution Policy

Altium Wealth Architecture Inc. (“Altium”) takes very seriously client satisfaction and makes sure that any Complaints (as defined below) are processed fairly and in a timely manner.

Altium’s policies with respect to processing complaints and dispute resolution (the “Complaint Policy”) complies with all applicable regulatory requirements, which may differ depending on your province of residence. For that reason, clients residing in the Province of Québec must consult Section A. while clients residing outside the Province of Québec must consult Section B.

Altium’s Complaint Policy covers Altium’s portfolio management activities and its financial planning activities.

For any questions about the Complaint Policy or to file a Complaint, please contact us via email, phone or mail.

Attention of: Compliance Department

E-mail:          [email protected]

Phone:          514.612.0122

Mail:             1130 Sherbrooke Street West, Suite 400, Montréal (Québec) H3A 2M8

A. For Clients Residing in the Province of Québec

  1. What is a Complaint?

A “Complaint” is the expression of a reproach or dissatisfaction by a client in respect of the services or products we offer and your expectation that we take action to address the complaint.

  1. How to File a Complaint?

You can file a complaint with us by whichever means is convenient for you using the contact information provided above. You may also use the Autorité des marchés financiers (“AMF”)’s form or contact us to find out how we process Complaints and we can help you file your Complaint.

  1. What are the Steps in the Complaint Process?

For certain Complaints, we may follow a simplified process whereby we try to propose a means of resolving the situation. The simplified process is described in Section 4 below. If we are unable to resolve your Complaint according to this process or if the nature or complexity of your Complaint is such that the Complaint does not lend itself to the simplified process, then the Complaint is processed according to the following steps.

i. We acknowledge receipt of your Complaint

We send you an acknowledgement of receipt in writing within 10 days of receipt of your Complaint.

ii. We analyze the Complaint

We make sure we understand your Complaint and what you expect from us. If necessary, we will contact you to request additional information.

iii. We provide a written final response

We provide you with a final response in writing within 60 days. In our response, we explain how we analyzed your Complaint, what led to our response and, if applicable, the proposed solution to your Complaint. You can always contact us if you have any questions or comments regarding our final response.

Extension of the period for providing our final response

Your Complaint may take longer to process or be more complex than anticipated, in which case we may determine that additional time is required for the analysis of your Complaint. The additional time may not exceed 30 days. In that case, we will notify you in writing, indicating the circumstances warranting the extension.

iv. Assessment of the offer and resolution of the Complaint

You can take time to review our response or assess our offer to resolve your Complaint. If we present an offer, we will give you time to assess and respond to it. The amount of time we give you will provide you with sufficient opportunity to seek the advice you need to make an informed decision. You can decide to accept or refuse the offer, or you can present a counteroffer.

Once we reach an agreement with you to resolve your Complaint, we must give effect to the offer within 30 days unless we agree upon a different time period with you when it is in your interest to do so.

v. Examination of the complaint record by the AMF

For each Complaint, we create a record in which we keep all the information or documents required for the processing of your Complaint.

You can contact us to request to have your Complaint record examined by the AMF at any time if you are not satisfied with the response we provided or how your Complaint was processed. We are required to send your Complaint record to the AMF no later than 15 days following receipt of your request.

  1. Simplified process for certain Complaints

As mentioned above, we may follow a simplified process for certain Complaints. This process is for Complaints that we can resolve to your satisfaction within 20 days.

We consider a Complaint to be resolved to your satisfaction when you accept our proposed solution to your Complaint or when the explanations we provide to you are sufficient to resolve your Complaint. Under the simplified process, Complaints may be referred to a member of our client service team and be handled verbally (e.g. in a phone call).

If we cannot propose a satisfactory solution or provide explanations sufficient to resolve your Complaint under this simplified process, we will notify you in writing. Your Complaint will continue to be processed, but in accordance with the steps in the Complaint process described earlier.

The time that we take when trying to resolve your Complaint under the simplified process does not have any effect on our obligation to provide you with our written final response within the required time period.

B. For Clients Residing Outside the Province of Québec

  1. What is a Complaint?

A “Complaint” means the complaint of a client that relates to Altium’s trading or advising activity or those of an employee that is received by Altium within six (6) years of the day when you first knew (or reasonably ought to have known) of an act or omission that is a cause of or contributed to the Complaint.

  1. How to File a Complaint?

You can file a Complaint with us by whichever means is convenient for you using the contact information provided above.

  1. Acknowledgment of Receipt

If Altium receives a Complaint, it will, as soon as possible, provide you with a written acknowledgement of the Complaint that includes the following:

i. a description of Altium’s obligations under its Complaint Policy;

ii. the steps that you must take if you wish that an independent dispute resolution or mediation service to be made available to you; and

iii. the name of the independent dispute resolution or mediation service that will be made available to you and contact information for the service.

  1. Written Notice of the Decision

If Altium decides to reject a Complaint or to make an offer to resolve a Complaint, it must, as soon as possible, provide you with written notice of the decision and include the information referred to in Section 2.

  1. Independent Dispute Resolution of Mediation Service

Altium must as soon as possible ensure that an independent dispute resolution or mediation service is made available to you at Altium’s expense with respect to a Complaint if either of the following apply:

  1. after 90 days of Altium’s receipt of the Complaint, Altium has not given you a written notice of a decision under Section 3, and you have notified the independent dispute resolution or mediation service specified that you wish to have the Complaint considered by the service; or
  2. within 180 days of your receipt of a written notice of Altium’s decision under Section 3, you have notified the independent dispute resolution or mediation service that you wish to have the Complaint considered by the service.

The Ombudsman for Banking Services and Investments (“OBSI”) is the service that will be made available to you by Altium.

Section 5 does not apply unless you agree that any amount you will claim for the purpose of OBSI’s consideration of the Complaint will be no greater than $350,000.

Last Updated: July 2025