1. Purpose of the Policy

The purpose of this policy is to outline Lockton Brokers ULC's ("Lockton Canada") Complaint Handling and Dispute Resolution Policy and Process. This policy establishes a framework to ensure that customer complaints are reviewed and resolved fairly by Lockton Canada. This includes:

• Providing a complaint processing service that is accessible and easy for customers to use.

• Demonstrating transparency and providing detailed information to customers so they understand how their complaints are handled.

• Managing complaints from receipt to resolution, with clear communication on the outcome of Lockton Canada's investigation.

This policy is also intended to help improve our services by identifying common causes of customer complaints so that appropriate solutions can be implemented to address systemic service delivery issues. This policy applies to all Lockton Canada personnel and must be implemented, disseminated, and applied across the organisation.

2. Our Complaints Team

Lockton Canada's Customer Success Consultant ensures complaints are processed fairly so that:

• Customers can readily obtain information on how complaints are handled and processed.

• Appropriate staff members are assigned to handle complaints.

• Staff understand and consistently apply this Complaint Handling and Dispute Resolution Policy.

• Each complaint is handled objectively and with consideration of the customer's interests.

3. What We Consider a Complaint

A complaint is an expression of reproach or dissatisfaction regarding a service and/or product offered by Lockton Canada or its affiliates, where the customer expects action to be taken to investigate the concern. The following are examples of requests or comments that are not considered complaints:

• Requests for information or materials regarding a product or service.

• Claims for indemnity or insurance claims.

• Requests to correct a clerical error or calculation mistake (unless further action is required to address resulting impacts).

• Requests to access or amend personal information.

• General comments or feedback about Lockton Canada.

4. Steps in the Complaint Process

Lockton Canada processes complaints fairly and objectively, free of charge, while considering the customer's interests. Communication is conducted in clear and plain language, and assistance is provided where required to help customers submit complaints. Customers may submit a complaint through any of the following methods:

Online

Submit an online complaint escalation form at:https://global.lockton.com/ca/en/contact-us (opens a new window)

Email

complaints_english_Canada@lockton.com (opens a new window)

Phone

(818) 482-4086

Mail

Lockton Brokers, ULC
Attention: Lockton Canada Complaint Resolution Program
C/O Dentons
250 Howe Street
Vancouver, BC V6C 3S9

Québec Residents

Complaints may also be submitted using the Autorité des marchés financiers (AMF) complaint form:https://lautorite.qc.ca/en/general-public/assistance-and-complaints/making-a-complaint (opens a new window)

5. Receipt of a Complaint

All customer complaints are entered into Lockton Canada's complaint register for tracking purposes. Lockton Canada will acknowledge receipt of a complaint in writing within 10 days and ensure it is promptly assigned to the appropriate personnel for investigation and handling under the supervision of the Complaints Officer.

For Residents of Québec

The acknowledgement of receipt will include:

• The complaint record identification code.

• The date the complaint was received.

• Information on how to obtain updates regarding complaint processing.

• The expected processing timeframe and the date by which a final response will be provided.

• A link to this policy.

• Information regarding the customer's right to have their complaint record examined by the AMF.

6. Complaint Handling

Upon receipt of a complaint, the Customer Success Consultant will:

• Enter the complaint into Lockton Canada's complaint register.

• Engage the appropriate personnel under the supervision of the Complaints Officer within one business day.

• Monitor progress towards resolution within 20 calendar days.

• Ensure the results of the investigation and proposed resolution are documented.

• For Québec residents, ensure customers are informed of their right to request transfer of their complaint record to the AMF within 10 business days.

Complaints Not Resolved Within 20 Days

If the complaint cannot be resolved to the customer's satisfaction within 20 calendar days, Lockton Canada will send written notice no later than the twentieth day following receipt of the complaint. The notice will include the information normally provided in the acknowledgement of receipt, and the complaint will be transferred to the Complaints Officer for formal handling.

Formal Complaint Process

The Customer Success Consultant will:

• Enter the complaint into Lockton Canada's complaint register.

• Send a formal acknowledgement letter within 10 business days.

• Provide a final written response following completion of the investigation, including:

  • A summary of the complaint.

  • Findings from the investigation.

  • The rationale supporting the final outcome.

A final response will be issued no later than 60 calendar days after receipt of the complaint.

Extensions to the Investigation

Where exceptional circumstances or factors beyond Lockton Canada's control prevent completion of the investigation within 60 days:

• The customer will be notified in writing by the 60th day.

• The notice will explain the reasons for the delay.

• A revised response date will be provided.

• The customer will be informed of their right to request examination of the complaint by the AMF.

Any extension may not exceed 90 calendar days from the date the complaint was received.

Resolution Offers

If a resolution offer is made:

• Customers will be provided with a reasonable period to evaluate and respond.

• Once accepted, Lockton Canada will implement the resolution within 30 days, unless another timeframe is agreed.

Additional Information Requests

If a customer fails to provide information or documentation required to investigate the complaint:

1. A formal request will be issued asking that the required materials be provided within 10 days.

2. If no response is received, a final notice will be sent advising that the complaint will be closed until the required information is received.

7. Transfer of a Complaint to the AMF or Other Third-Party Dispute Resolution Organisation

If a customer is dissatisfied with either:

• The final response received from the Customer Success Consultant; or

• The manner in which their complaint was handled,

they may request that the AMF or another applicable third-party dispute resolution organisation review their complaint. Lockton Canada will forward the complaint file to the AMF within 15 days of receiving the customer's request and will comply with all applicable Québec regulatory requirements.

For Residents of Québec

Autorité des marchés financiers (AMF)
Website: https://lautorite.qc.ca/en/general-public/assistance-and-complaints/making-a-complaint (opens a new window)
Telephone: 1-877-525-0337

8. Effective Date

This policy is effective 30 July 2026.