Complaint Handling Procedures

Mandeville Private Client Inc.

Mandeville Private Client Inc. (“Mandeville”) has developed policies and procedures for the purpose of ensuring that all complaints are handled in a transparent, equitable and timely manner. It is important that you are comfortable contacting us whenever you have questions or concerns as your business and on-going relationship are very important to us.

Complaints include alleged grievances relating to Mandeville or one of its Investment Advisors and are: (1) recorded expressions of dissatisfaction with Mandeville or an employee or agent alleging misconduct; and (2) a verbal expression of dissatisfaction with Mandeville or an employee or agent alleging misconduct where a preliminary investigation indicates that the allegation may have merit.

Alleged misconduct includes, but is not limited to, allegations of breach of confidentiality, theft, fraud, misappropriation or misuse of funds or securities, forgery, unsuitable investments, misrepresentation, unauthorized trading, inappropriate financial dealings with clients and engaging in securities-related business outside of Mandeville.

You are invited to submit details of your complaint in writing to the following address:

Mandeville Private Client Inc.
Attn: Chief Compliance Officer
1375 Kerns Road, Suite 200
Burlington, ON L7P 4V7
(905) 331-4255, ext 7001

Mandeville has established the following process to ensure the efficient handling of complaints:

Service-related complaints (i.e. customer service-based concerns) may be assigned to the designated Supervisor in a business location or to Head Office staff as appropriate.

Securities-related verbal complaints will lead to a request for the client to provide information in writing however Mandeville will commence its complaint review before receipt of the written complaint.

Securities-related complaints – whether written or verbal – will result in Mandeville recording the complaint in its complaint database and acknowledging the complaint in writing within five (5) business days of receipt of the complaint. See Appendix A for a sample Client Complaint Acknowledgement letter.

Both the Mandeville Investment Advisor and Supervisor will be notified of the complaint and requests will be made for all documentation in respect of the complaint.

Allegations of a more serious nature, including legal action, are reported to Mandeville senior management.

Mandeville commences a review of the allegations contained in each complaint and endeavours to provide substantive responses within ninety (90) days of receipt of the complaint. The complaint review is conducted by qualified compliance staff who operate in an objective manner and who consider the separate facts of each complaint.

Mandeville may contact the client at any time to request additional information or to clarify specific statements or facts.

Should Mandeville require additional time beyond three (3) months to review and respond to a complaint, we will communicate the cause of the delay and provide a revised timeline to the client.

Care is taken to ensure that each complaint receives an appropriate and substantive response.

The response letter will also include the following statement:

““We remind you that there are options available to you if you are not satisfied with our response, including (i) arbitration; (ii) presenting your complaint to the Ombudsman for Banking Services and Investments which will consider complaints brought to it within six (6) months of this letter; (iii) making a complaint to the Investment Industry Regulatory Organization of Canada (“IIROC”); (iv) retaining a lawyer to assist you with your complaint; and (v) other applicable options. In accordance with IIROC regulations, we are enclosing a brochure entitled “An Investor’s Guide to Making a Complaint” (a copy of this brochure was also provided to you with our letter dated “X”).

Appendix A

“Client Complaint Acknowledgment”

Client Name



Dear [Client Name]:

Re: Letter of complaint dated [insert date]

Mandeville Private Client Inc. (“Mandeville”) is writing to acknowledge receipt of your letter of complaint on [insert date of receipt of complaint].

Mandeville has commenced a review of your complaint and will respond to you in writing at the conclusion of our investigation. We expect to deliver a substantive response within ninety (90) days. We may contact you to request additional information. Should the investigation be delayed due to its complex nature or due to delays in receiving requested information, we will communicate such delays to you.

You are invited to contact me at any time in respect of your complaint; my contact information is set out below.

In accordance with IIROC regulations, please find enclosed a brochure entitled “An Investor’s Guide to making a Complaint.”

Yours truly,

Alison Fletcher
Chief Compliance Officer