Complaints Handling

A complaint is a formal declaration of dissatisfaction with Sterna Asset Management Inc. (“STERNA”), one of its employees, or a representative regarding misconduct related to an advisory activity. Complaints must be submitted within six years from the discovery of the incident. Alleged misconduct may include:

• Breach of confidentiality
• Theft, fraud, misappropriation, or unauthorized use of funds or securities
• Forgery, unsuitable investments, false or misleading information
• Unauthorized transactions in client accounts
• Unauthorized activities conducted outside of STERNA

STERNA has established a client complaint handling framework that complies with applicable regulatory standards. This ensures that clients reporting misconduct related to their account management receive an impartial review and have access to various resolution options.

A complaint must include:

• A description of the alleged misconduct
• The harm suffered
• The corrective measure requested

STERNA will acknowledge receipt of the complaint in writing within five (5) business days and record it in its complaints database. A thorough review of all relevant facts will be conducted. STERNA will decide whether to reject the complaint, propose a resolution, or make a settlement offer within 90 calendar days of receiving the complaint.

If STERNA believes it cannot provide a final response within this timeframe, it will inform the complainant of the delay, its reasons, and the new estimated resolution date.

The detailed response to the complainant will be fair, clear, and not misleading. It will include:

• A summary of the complaint
• The findings of STERNA’s investigation
• STERNA’s final decision with an explanation
• The complainant’s options if they are unsatisfied with STERNA’s response

Complaints can be submitted via email to: plaintes@sternafinance.ca.

Additional Resolution Methods After Filing a Complaint with STERNA Mediation (AMF – Québec Residents Only)

For residents of Québec, the Autorité des marchés financiers (AMF) offers a free mediation service to help resolve disputes. Participation in this service is voluntary. Within 10 days of registering a complaint, STERNA must inform the complainant of their right to request mediation.

Complainants who are dissatisfied with how STERNA handled their case may request the AMF to review their complaint. With the consent of all parties, the AMF may act as a conciliator or mediator, but it does not have decision-making authority.

Contact Information for the AMF:

Autorité des marchés financiers
Place de la Cité, Cominar Tower
2640, boul. Laurier, Bureau 400
Sainte-Foy, QC G1V 5C1
Toll-Free: 1-877-525-0337
Québec: 418-525-0337 | Montréal: 514-395-0337
Email: renseignements-consommateur@lautorite.qc.ca
Website: www.lautorite.qc.ca

Arbitration

STERNA cannot impose arbitration on a client but must agree to arbitration for claims of $500,000 or less. Private arbitration is possible for any amount if both parties agree. Legal representation is permitted, and the arbitrator's decision is final and binding. Arbitration outcomes must be recorded in the ComSet complaint and settlement tracking system. Each party shares the costs and fees equally.