Complaint Policy

This policy applies to all complaints received from clients, agents, and other stakeholders regarding the products and services offered by Greatway.

This policy shall be reviewed by Management annually or as required based on regulatory updates.

A complaint is any written or verbal communication expressing dissatisfaction regarding a product, service, or conduct of Greatway or its representatives, where the reproach or dissatisfaction is communicated by a member of the clientele and a final response is expected.

This encompasses issues related to but not limited to the following: breach of confidentiality, theft, fraud, misappropriation of funds, forgery, unsuitable investments, misrepresentation, and inappropriate or unethical conduct.

*The following are not considered complaints:

1. a request made for information or materials in respect of an offered product or service;

2. a request for access or rectification made in accordance with the Act respecting the protection of personal information in the private sector (chapter P-39.1);

3. a claim for an indemnity or any other insurance claim;

4. a request for correction of a clerical error or mistake in calculation; and

5. communication of a comment or feedback

*SEC. 3. Regulation respecting complaint processing and dispute resolution in the financial sector, AUTORITÉ DES MARCHÉS FINANCIERS

As required by regulation, Greatway shall appoint a designated complaint resolution officer with the necessary experience and authority to oversee the complaint-handling process. This individual ensures that complaints are managed by appropriate personnel, such as supervisors or compliance staff, and that the process is conducted impartially, confidentially and within a reasonable timeframe.

Greatway’s Compliance Office shall serve as the receiving center for all complaints and shall oversee the processing and resolution of complaints in coordination with the relevant Greatway department or proper escalation thereof to the appropriate authority.

When you file a complaint, you should:

• Provide your name and policy number

• Provide the name of the agent or broker if you didn’t deal directly with a company representative

• State the facts, such as why you think there is a problem and what you'd like to happen

• Provide copies of documents, such as account statements, contracts and medical information, if needed

• Keep a record of who you talked to and what they said

• Ask for a letter that clearly states your insurer’s final decision regarding your complaint

Greatway warrants that all complaint resolution process shall be conducted in an objective manner, taking into account the interests of the complainant, uses clear and simple language and kept free of charge for the complainant.

Step 1: Acknowledgement

• Complaints can be submitted via email, mail, telephone, or in person.

• The complaint is logged in the Complaint Register within two (2) business days of receipt.

• An acknowledgement letter/email is sent to the complainant within five (5) business days, confirming receipt and providing the contact details of the assigned complaint handler.

Step 2: Investigation

• The complaint is assigned to a designated complaint resolution officer.

• Relevant documents and details are gathered from all involved parties.

• The officer conducts a fair and impartial investigation, ensuring all aspects of the complaint are considered.

Step 3: Resolution

• A written response outlining the investigation findings and resolution is provided to the complainant not later than 60 calendar days following the receipt of the complaint.

• If additional time is required, the complainant is informed of the delay and provided with an updated timeline not to exceed 90 calendar days from the time of receipt.

• If the complainant is dissatisfied with the resolution, they are advised of their right to escalate

If the complainant is unsatisfied with the initial resolution, they may escalate their complaint to senior management for further review.

If unresolved, the complainant may escalate the matter to the appropriate provincial insurance regulator (e.g., FSRA in Ontario, AMF in Quebec) or the OmbudService for Life & Health Insurance (OLHI). See list of agencies on Appendix A.

• In line with industry best practice, complaints and their resolutions are documented and retained for a minimum of seven (7) years.

• Periodic reports on complaints shall be reviewed by senior management to identify trends and improve processes.

• Reports shall include the following:

  • the number of complaints received and processed and the causes common to the complaints;

  • the outcomes of the complaint process;

  • issues related to the implementation and dissemination of, and compliance with, the policy; and

  • issues identified when ascertaining the causes common to the complaints that are processed.

Greatway warrants that in the event that it offers the complainant with an offer to resolve the complaint, no conditions shall be attached which:

1. Prevents the complainant from exercising their right to have the complaint record examined by a lawful regulatory authority;

2. Requires the complainant to withdraw any other complaint they have filed; or

3. Prevents the complainant from communicating with a lawful regulatory authority.

Complaint trends and root causes are analyzed to enhance customer service and mitigate recurring issues.

Employees handling complaints shall receive regular training on best practices, regulatory compliance, and customer service.

All complaints are handled confidentially, and personal information is protected in accordance with applicable privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial legislation.

Complainants may submit their concerns through the following channels:

By email at: compliance@greatwayfinancial.com
Phone: 1-800-545-0013 Ext. 6 or 416-901-0305
By mail to the attention of:
Greatway Financial Compliance 1223 31 Ave NE, Calgary AB T2E 7W1

If you are not satisfied with the outcome, you may pursue this matter with any of the following external resources:

• OmbudService for Life & Health Insurance (OLHI)
  Address: 2 Bloor St. West, Suite 700 Toronto, ON M4W 3E2
  Attention: General Manager
  Phone: 416-777-9002
  Toll free: 1-888-295-8112
  Bell Relay Service (Hearing Impaired): 1-800-855-0511
  Web: www.olhi.ca 

• Ombudsman des assurances de personnes
  Address: 2001, boul. Robert Bourassa, 17e étage, Montréal (Québec) H3A 2A6
  Attention: À l’attention de la Directrice générale
  Phone : 514-282-2088
  Toll free: 1-866-582-2088
  Bell Relay Service (Hearing Impaired): 1-800-855-0511
  Web: www.oapcanada.ca 

• Financial Consumer Agency of Canada
  Address: Enterprise Building, 427 Laurier Ave. West, 6th Floor, Ottawa, Ontario K1R 1B9
  Toll-free English: 1-866-461-3222 ,
  Toll-free French 1-866-461-2232
  Web: www.fcac.gc.ca 

• Financial Services Regulatory Authority of Ontario
  Address: 5160 Yonge Street, 16th floor, Toronto, ON M2N 6L9
  Phone: 416-250-7250 or
  Toll-free: 1-800-668-0128
  Email: contactcentre@fsrao.ca
  Web: www.fsrao.ca/contact-us 

• Autorité des marchés financiers (AMF), for Quebec Residents
  Autorité des marchés financiers
  Address: Place de la Cité, tour Cominar, 2640, boulevard Laurier, bureau 400, Québec, G1V 5C1
  Phone: 418-525-0337Fax: 418-525-9512
  Web: www.lautorite.qc.ca 

• Autorité des marchés financiersAddress: 800, square Victoria, 22e étage, C.P. 246, tour de la Bourse, Montréal, QC, H4Z 1G3
  Phone: 514-395-0337
  Toll free: 1-877-525-0337
  Fax: 514-873-3090
  Web: www.lautorite.qc.ca 

• Financial and Consumer Affairs Authority, for Saskatchewan Residents
  Superintendent of Insurance, Insurance and Real Estate Division
  Financial and Consumer Affairs Authority
  Address: Suite 601, 1919 Saskatchewan Drive, Regina, Saskatchewan S4P 4H2
  Phone: 306-787-6700Fax: 306-787-9006
  Email: fid@gov.sk.caWeb: https://fcaa.gov.sk.ca/