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Pembroke Management Complaint Handling Procedure

Pembroke Management Ltd. (PML) is committed to resolve concerns that our clients may have with our products or services.

PML has procedures in place to handle any written or verbal complaints received by clients in a fair and prompt manner. This is a summary of those procedures, which we provide to new clients and clients who have filed a complaint.

A complaint is the expression of a reproach or dissatisfaction in respect of a product or service offered by PML, communicated by a client, where action or a response is expected.

Any informal step to correct a particular problem is not a complaint, insofar as the problem is settled as part of PML’s regular activities and without the filing of a complaint by the client.

Persons having an interest in a service provided by a portfolio manager who are not satisfied with a service have a right to make a complaint and to seek resolution of the problem. Portfolio managers, such as PML, have a responsibility to their clients to ensure that all complaints are dealt with fairly and promptly. PML will provide reasonable assistance to clients throughout the complaint process, including assistance in submitting a complaint where required, and will provide timely updates on the status of the complaint.

If you have a complaint, these are some of the steps you can take:

How to File a Complaint Directly with Pembroke Management Ltd.

Firms such as PML are responsible to you, the client, for monitoring the actions of their representatives to ensure that they are in compliance with by-laws, rules and policies governing their activities. PML will investigate any complaint that you initiate and respond back to you with the results of their investigation.

If you have a complaint about our services, please contact us at:

  • Chief Compliance Officer
  • Pembroke Management Ltd.
  • 150 King Street West, Suite 1210
  • Toronto, Ontario, M5H 1J9
  • Email: compliance@pml.ca
  • Phone: 416-366-2550 or toll-free at 800-668 7383

We encourage clients to make their complaint in writing or by e-mail where possible. Where clients have difficulty putting their complaint in writing, they should advise us so that we can provide assistance. For confidentiality reasons, we will only deal with the client or another individual who has the client’s express written authorization to deal with us.

We will acknowledge receipt of complaints promptly, generally within five days. We review all complaints fairly, taking into account all relevant documents and statements obtained from the client, our records, or other staff members and any other relevant source. Once our investigation is complete, we provide clients with our response, which will be in writing if the complaint was made in writing. Our response may be an offer to resolve your complaint, a denial of the complaint with reasons or another appropriate response. Where the complaint relates to certain serious allegations, our initial acknowledgement will include copies of this summary and the Client Complaint Information Form. Our response will summarize your complaint, our findings and will contain a reminder about your options with the Ombudsman for Banking Services and Investments.

We will generally provide our final response within 90 days of receiving your complaint. If your complaint is subject to Québec’s complaint-handling regime, we will provide our final response no later than the 60th day following receipt of the complaint, unless extended to no later than 90 days in exceptional circumstances or circumstances beyond our control (in which case we will inform you of the reasons for the extension).

We will respond to communications you send us after the date of our response to the extent necessary to implement a resolution or to address any new issues or information you provide.

If we offer you a financial settlement, we may ask you to sign a release and waiver for legal reasons.

If you have a complaint about our services and are not satisfied with the response that you have received from Pembroke, you have several options.

How to File a Complaint with the Ombudsman for Banking Services and Investments

Ombudsman for Banking Services and Investments (“OBSI”): After PML’s Compliance Department has responded to your complaint, you may contact OBSI. You may also contact OBSI if PML’s Compliance Department has not responded within the applicable timeframe described above. OBSI provides an independent and impartial process for the investigation and resolution of complaints about the provision of financial services to clients. OBSI can make a non-binding recommendation that your firm compensate you (up to $350,000) if it determines that you have been treated unfairly, taking into account the criteria of good financial services and business practice, relevant codes of practice or conduct, industry regulation and the law. The OBSI process is free of charge and is confidential. OBSI can be contacted:

Phone: (416) 287-2877 or toll-free (888) 451-4519

E-mail ombudsman@obsi.ca

Website: www.obsi.ca

Residents of Manitoba, New Brunswick and Saskatchewan may consider

Manitoba, New Brunswick, and Saskatchewan: Securities regulatory authorities in these provinces have the power to, in appropriate cases, order that a person or company that has contravened securities laws in their province pay compensation to a claimant. The claimant is then able to enforce such an order as if it were a judgment of the superior court in that province. For more information, please visit:

Manitoba: mbsecurities.ca

New Brunswick: www.nbsc-cvmnb.ca

Saskatchewan: www.fcaa.gov.sk.ca

Residents of Quebec may consider

In the province of Quebec, the regulatory body is the Autorité des marchés financiers (“AMF”), clients residing in Quebec, may at their request, ask PML to transfer their complaint file to the AMF, if they are dissatisfied with the outcome of the examination of their complaint or the examination itself. PML will transfer the client’s complaint file to the AMF within 15 days of receiving their request. The AMF may also offer mediation for an amicable settlement if it deems it appropriate and all parties agree. The filing of a complaint with the AMF does not interrupt the prescription relating to recourses against PML before civil courts.

The AMF pays indemnities to victims of fraud, fraudulent tactics, or embezzlement where those responsible are individuals or firms authorized to practice under the legislation governing the provision of financial services in Quebec. It also rules on the eligibility of claims and sets the amount of the indemnities to be paid to victims. Consumers can thus be compensated to a maximum of $200,000 per claim, through funds accumulated in a financial services compensation fund.

The AMF can be contacted:

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