At Orbit, we are committed to maintaining the trust of our clients. This policy is designed to ensure that any complaints we receive are handled fairly, transparently and efficiently, while promoting the continuous improvement of our services.

Policy objectives

1. Offer our clients a free, accessible and easy-to-use complaints handling service.
2. Provide them with all the information they need to understand our handling process.
3. Ensure a rigorous and impartial follow-up of each complaint received.
4. Identify recurring causes of dissatisfaction in order to prevent problem situations in the future.

What is a complaint?

A complaint is an expression of dissatisfaction by a client regarding a service or product. It includes a request for correction, refund, apology, or any other form of corrective action.

The following are not considered complaints:

1. A request for information or documents.
2. An insurance claim.
3. A request for administrative correction.
4. A request for access or modification of personal information.
5. A simple comment or remark.

Filing a complaint

Before initiating a formal complaint process, it is recommended to first attempt to resolve the issue by speaking directly with the representative involved. If the proposed solution is unsatisfactory, you may request the intervention of a manager or supervisor. This approach generally leads to a quicker and more efficient resolution.

All complaints must be submitted either directly or by using the form provided by the Autorité des marchés financiers (AMF).

Contact details for our complaints officer:

Maxime Chouinard-Fortin

mchouinard-fortin@orbite.ca

Montreal: 407 McGill St., Suite 610, Montreal, QC H2Y 2G3

Drummondville: 110-1835 Lemire Blvd., Drummondville, QC J2C 5A6

Treatment steps

1. Initial assessment: We analyze the communication to determine whether it is a formal complaint.
2. Handling: The complaint is recorded in our official complaints register.
3. Acknowledgement: The client receives written confirmation within 10 days, including next steps and right of recourse to the AMF.
4. In-depth analysis: We gather all relevant information to understand the situation and propose a fair response.
5. Final written response: Provided within a maximum of 60 days. If a more complex analysis is required, an additional 30 days may be applied, with prior written notice to the client.
6. Resolution: Three types of response are possible:
   1. Full acceptance of the client's request.
   2. Offer of compromise.
   3. Reasoned rejection of the complaint.

We will continue to respond to any questions or new information submitted, even after our reply has been sent.

Streamlined Process

We have introduced a streamlined process to handle certain complaints for which we can provide a satisfactory resolution within 20 days. A complaint is considered resolved to your satisfaction if you accept the proposed solution or if our explanation addresses your concerns.

These complaints may be handled by a client service representative or a dedicated team and may be resolved, for example, during a phone call.

If we are unable to offer a solution or provide an explanation that resolves your complaint, we will notify you in writing, and the complaint will then proceed according to the steps outlined above.

This streamlined process does not affect our obligation to provide you with a final written response within the required timeframes.

External recourse: the AMF

Clients that are dissatisfied with our handling or decision may request that their file be examined by the Autorité des marchés financiers (AMF). We will then transfer the file within 15 days of the request.

Our proactive approach

1. We keep an up-to-date record of all complaints received.
2. We train our employees to recognize and deal effectively with complaints.
3. We assign each complaint to a competent person, under the supervision of the designated person in charge.
4. We analyze complaints to prevent recurrence and improve our practices.

Special cases

1. If the complaint concerns another party (insurer or other firm), we notify the client and invite him or her to address his or her complaint to that party as well.
2. If the situation raised by the complaint may affect other clients, we take the necessary steps to correct the situation on a larger scale.

Employee responsibilities

Any employee or representative who receives a complaint must:

1. Forward it without delay to the persons responsible.
2. Actively cooperate in handling the complaint.
3. Provide the information required for a complete analysis.

Policy updated on August 26, 2025

A copy of this policy is available upon request.