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Complaints

R.J. O'Brien & Associates Canada Inc. ("RJO Canada") has created an internal process for documenting, handling and resolving complaints in an efficient and expedient manner. The process has been designed to meet or exceed legal and regulatory requirements.

COMPLAINTS GENERALLY

The fair and timely handling of client complaints is vital to the overall integrity of the investment industry. RJO Canada regards the handling of all client complaints as an essential element of the proper servicing of client accounts generally, and believes an effective framework for dealing with client complaints is in keeping with appropriate standards of professionalism for the industry.

WHAT CONSTITUTES A COMPLAINT

A "complaint" can be against RJO Canada, the Account Executive on the account, or any other employee of RJO Canada.
A complaint is any verbal or recorded expression of dissatisfaction alleging misconduct.

A mistake or oversight is not misconduct.

The following are defined as misconduct:

• allegations of breach of confidentiality
• theft, fraud
• misappropriation or misuse of funds or securities
• forgery
• unsuitable investments
• misrepresentation
• unauthorized trading relating to the client's account(s)
• other inappropriate financial dealings with clients

Step 1 - Contact your Investment Advisor

In many instances complaints may be simple misunderstandings and may be resolved quickly and over the telephone or in person. As a first step, please contact your Account Executive if you have questions or concerns about a particular issue.

Step 2 - Send us your complaint in writing

If the problem you have is not solved to your satisfaction after completing Step 1, please detail your complaint in writing and send it to us. Your correspondence should be sent to the branch office where your Investment Advisor works (to his or her attention), with a copy of the complaint also sent to the attention of the Branch Manager at that branch office and a copy should also be sent to:

R.J. O'Brien & Associates Canada Inc.
Suite 1103, 220 Portage Avenue
Winnipeg, MB R3C 0A5
Canada

Attention:
Lora Miller
Chief Compliance Officer/Designated Complaints Officer

Once we have your complaint in writing it will be handled in accordance with our complaint process. Within 5 business days of our receipt of your complaint you will receive an acknowledgement of your complaint from the Designated Complaints Officer with a description of next steps to be taken by us as well as other information such as a designated contact person, complaint reference number, the protocol you should follow once you have sent your complaint to us and the timelines which we follow in order to process your complaint in a timely manner. The entire process should take no longer than 90 days before you are in receipt of a substantive response letter from the Designated Complaints officer, which will including the following information;

1. A summary of your complaint
2. The results of our investigation
3. Our final decision on the complaint, including an explanation; and
4. A statement describing your options available to you should you not be satisfied with our response

Step 3 - Other options available to you

If, following Step 2, your complaint has not been resolved to your satisfaction there are other options available to you (IIROC Enforcement, Ombudsman for Banking Services, (“OBSI”), and Arbitration). OBSI will consider a client complaint at the earlier of:
(i) the date the complaint substantive response is provided to the client; or
(ii) ninety (90) days after the receipt of the complaint.