1. Purpose of the policy
The purpose of this complaint examination and dispute resolution policy (hereinafter “the policy”) is to establish a simple procedure for dealing equitably with complaints and disputes received by or submitted to Groupe DPJL Damage Insurance Firm (hereinafter “Groupe DPJL”) in the course of its relations with its clients.
This policy governs the receipt of complaints, recording of complaints in a registry, delivery of the acknowledgment of receipt and other notices to the complainant, creation and content of the complaint file, and, as applicable, transfer of the file to the Autorité des marchés financiers (hereinafter “the AMF”). The policy also governs the compilation of complaints for the purpose of preparing and filing a twice-yearly report to the AMF using its Complaint Reporting System (CRS).
2. Person in charge
The person in charge of applying this policy within the Firm —Ms. Diane Rivard, Vice-President, Personal Lines Insurance (“the person in charge”)—acts as the respondent with the AMF and trains and instructs the Groupe DPJL’s staff on how to properly apply the policy.
3. The person in charge is also responsible for:
- delivering an acknowledgment of receipt and notice to the complainant;
- maintaining a registry of complaints for the Groupe DPJL;
- transferring a complainant’s file to the AMF, at the complainant’s request;
- filing a report twice a year with the AMF using the Complaint Reporting System (CRS).
4. Definition and receivability of a complaint
For the purposes of this policy, a complaint is the expression of at least one of the following three elements outstanding after the complaint has been handled at the appropriate operational level of the Groupe DPJL:
- a reproach against the Groupe DPJL or one of its employees;
- the identification of real or potential harm that a consumer has sustained or may sustain;
- a request for remedial action.
Note: An initial expression of dissatisfaction by a client, whether written or verbal, or an informal approach by them to correct a specific problem is not considered a complaint when the dissatisfaction is resolved at the appropriate operational level of the Groupe DPJL.
5. Receipt of the complaint
Clients who wish to file a complaint must do so either in writing at the following address:
Ms. Diane Rivard
Groupe DPJL Damage Insurance Firm
100 - 185, boul. St-Jean-Baptiste
Châteauguay, QC J6K 3B4
or verbally by telephone to 450-691-9913.
Any Groupe DPJL employee who receives a complaint as defined in point 4 above, must, upon receipt, refer it to the person in charge of applying this policy, who, in turn, must record it in the Groupe DPJL’s complaints registry.
The person in charge must acknowledge receipt of the complaint within five business days of receiving it.
The acknowledgment of receipt must contain the following information:
- a description of the complaint, specifying the real or potential harm, the reproach against the Groupe DPJL or one of its employees, the real or potential harm, and the requested remedial action;
- the name and contact information of the person in charge of examining complaints;
- in the case of an incomplete complaint, a notice requesting more information, to which the complainant must respond within ten days, failing which the complaint will be deemed to have been dropped;
- a copy of this policy;
- a notice stating that if the complainant is not satisfied with the examination or the outcome of the complaint, they can request that the complaint file be transferred to the AMF. This notice must also mention that the AMF may offer dispute resolution services, if deemed appropriate;
- A reminder to the complainant that filing a complaint with the AMF does not interrupt the prescribed period for seeking civil remedies against the Groupe DPJL.
6. File creation and content
An individual file must be created for each complaint recorded in the Groupe DPJL’s complaint registry.
The file must contain the following:
- the written complaint, including all the documents submitted by the complainant or a complete description of the complaint if verbal and with its three elements (the reproach against the Groupe DPJL, the real or potential harm, and the requested remedial action);
- the outcome of the complaint examination process (the analysis and the supporting documents);
- the final written response, including justifying reasons, that was forwarded to the complainant.
7. Examination of the complaint
Upon receiving a complaint, the Groupe DPJL must initiate the complaint examination process.
The complaint must be examined within 30 days of receiving all the necessary information for the examination.
After examining the complaint, the person in charge must send the complainant a final written response that includes justifying reasons.
8. Transfer of the file to the AMF
If the complainant is not satisfied with the examination or outcome of the complaint, they may, at any time, ask the Groupe DPJL to transfer the file to the AMF.
The transferred file must include all the information related to the complaint, as listed in point 6.
The person in charge must use the CRS to file a twice-yearly report with the AMF detailing the number and type of complaints received, regardless of whether any were received or not.
The reporting deadlines are:
- no later than July 30, for data collected between January 1 and June 30;
- no later than January 30, for data collected between July 1 and December 31.
10. Effective date
This policy came into effect on May 1, 2016.