Complaint Examination and Dispute Resolution Policy

The purpose of this policy is to inform clients about the procedures in place to ensure a free and fair procedure for the examination of complaints. This policy also intends to provide oversight for the receipt of complaints, delivery of acknowledgments of receipt, creation of complaint files, transfer of complaint files and compilation of complaints.

General

A complaint is any written statement from a current or former Client, (the "Complainant"), or person acting on behalf of a Complainant, alleging a grievance or dissatisfaction with any service offered by Richmond Asset Management or a representative of Richmond Asset Management ("Complaint")

The following will not be seen as official Complaints but should still be escalated to the Chief Compliance Officer for consideration:

1. Verbal Complaint: Where a Complainant makes a verbal complaint, a representative of Richmond Asset Management will ask the Complainant to submit the verbal complaint in writing such that it be seen as a Complaint.

2. Complaint about Performance: Richmond Asset Management does not guarantee performance. Accordingly, a decrease in portfolio holdings, while important from a business relationship standpoint, does not trigger the following Complaint process. An official Complaint must be with a service provided by Richmond Asset Management in terms of a failure to perform an expected task or the performance of an expected task.

Richmond Asset Management will document the complaint in its Complaints Log and reasonably respond to each Complaint made to Richmond Asset Management.

Complaints Procedure

The Chief Compliance Officer shall be the first person contacted with respect to a Complaint.

All Complaints and any other concerns received in writing must be entered onto a Complaint Form and given to the Chief Compliance Officer. The Chief Compliance Officer will enter the Complaint onto the Complaint Log.

If a Complaint is made verbally, and is not clearly expressed. the Chief Compliance Officer may request that the Complainant put the Complaint in writing in order to try to resolve confusion about the nature of the issue.

The Complaint file is to include a copy of any written correspondence from the Complainant, any notes taken during a verbal Complaint, and all follow up notes and memos regarding the Complaint. The file is to be retained for a period of seven years.

Within five business days of receipt of the Complaint, the Chief Compliance Officer will prepare an acknowledgement letter advising the Complainant of investigation initiation and confirming that a formal response will be forwarded within thirty (30) days.

It is Richmond Asset Management’s policy to fully resolve Complaints within ninety (90) days of receiving the Complaint.

Filing a complaint

A client who wishes to file a complaint may do so in writing to the following address:

DBAS Realco Inc.
250 University Avenue
2nd Floor
Toronto, Ontario M5L 1E2
Attention Chief Complain Officer

Telephone: 1.416.272.8559

E-mail: info@richmondam.ca