This procedure falls within the scope of the new amendments made to Dealer Member Rules 19, 37 and 2500 regarding the handling of complaints and the settlement of disputes, as approved by competent securities authorities.

PURPOSE OF THE PROCEDURE

The purpose of this procedure is to establish a procedure ensuring the free and equitable handling of all complaints received by Laurentian Bank Securities Inc., hereinafter referred to as “the regulated organization”. It is intended, more specifically, to provide a framework for the receipt of complaints, the delivery of the acknowledgement of receipt and the notice to the complainant, the creation of the complaint file, the transfer of this file to the Autorité des marchés financiers (hereinafter referred to as “the Autorité”) at the complainant’s request when applicable, and the filing of the complaint report with the Autorité.

PERSON IN CHARGE

The Chief Compliance Officer is responsible for the application of this procedure.

As the person in charge of the application of the procedure, the Chief Compliance Officer acts as a representative with regulatory authorities and is responsible for training staff and providing them with relevant information to ensure that this procedure is applied according to requirements.

In addition to the above-mentioned duties, the person in charge is responsible for:

• Acknowledging the receipt of complaints filed with the regulated organization within 5 business days.
• Sending the required notices.
• Recording and updating the facts pertaining to the complaint in the COMSET system.
• Transferring files to the Autorité, upon complainants’ request.
• Maintaining a complaints register.
• Sending an annual complaint report to the Autorité.
• Conducting an impartial investigation of the complaint and a through examination of the complaint.
• Assessing the basis of the complaint.
• Establishing the offer to be presented to the client when it is found that the complaint is substantiated.
• Taking any appropriate corrective action with the broker.

COMPLAINT

For the purposes of this procedure, a complaint must meet the three following conditions:

• It is filed by a client or by a person authorized to act on the client’s behalf.
• It represents a written or verbal expression of dissatisfaction.
• It alleges a misconduct purporting to the handling of the client’s account or account(s) or to the client-broker relationship.

Instances of misconduct are: breach of privacy, theft, fraud, misappropriation or illegal use of funds or securities, forgery, inappropriate investments, misrepresentation, or unauthorized transactions pertaining to clients’ accounts, other unauthorized financial transactions with clients and the conduct of securities related activities outside of the broker.

Shall not constitute a complaint any first-level intervention consisting in a consumer’s communication that is part of an informal process aimed at correcting a specific problem, provided that the issue is settled in the regular course of business, without the consumer being required to file a formal complaint.

To be receivable, a filed complaint, other than those relative to customer service, must be made in writing by the complainant.

Shall also be receivable a verbal complaint alleging misconduct when a preliminary investigation indicates that the allegation may be substantiated in some way.

RECEPTION OF COMPLAINT

Consumers who wish to file a complaint must do so in writing to the following address:

Laurentian Bank Securities Inc.
C/O Compliance Department
1981 McGill College Avenue
Suite 1900
Montréal, Québec
H3A 3K3
(514) 350-2800

Any employee who receives a complaint shall, upon reception, forward the complaint to the person in charge of the application of this procedure.

The person in charge acknowledges reception of the complaint within 5 business days. The acknowledgement of receipt shall include the following information:

• The name and contact information of the person in charge of examining the complaint and authorized to do so.
• An invitation to the client to communicate with the person in charge if they want to receive a progress report on their complaint.
• A copy of this procedure.
• A notice informing the complainant that they have the right to request the transfer of their file to the Autorité at the end of a period of 90 days following the reception of all required information or within one year of receiving the reply to their complaint. The notice must also mention that the Autorité may provide mediation services when the parties agree.
• A notice reminding the complainant that mediation is an alternative dispute resolution process through which a third party (the mediator) intervenes with the disputing parties to reach a satisfactory agreement.
• A notice informing the complainant that the filing of a complaint with the Autorité does not interrupt the prescription period for recourse by the complainant against the regulated organization before a civil court.
• A copy of the brochure entitled “Investor Protection for Clients of IIROC-Regulated Firms”.

CREATION OF COMPLAINT FILE

A distinct file must be created for each complaint received. The file shall include the following elements:

• The complainant’s written complaint, including the three elements of the complaint (the reproach made to the regulated organization, the real of potential harm sustained and the remedial action requested).
• The result of the complaint handling process (analysis and support documents).
• Copy of the final and justified answer forwarded in writing by the regulated organization.

COMPLAINT HANDLING

Upon reception of a complaint, the regulated organization conducts an investigation. The complaint shall be handled within a reasonable 90-day delay following the reception of all required information. At the end of the investigation, the person in charge forwards to the complainant a written, final and justified answer. A copy of this procedure is enclosed with the detailed answer.

FORWARDING OF FILE TO THE AUTORITÉ

When a complainant is dissatisfied with the examination of his or her complaint by the regulated organization or with the outcome of the examination, he or she may request that the latter forward his or her complaint file to the Autorité. This right may not be exercised by the complainant until the delay provided for the reception of a final answer has expired or, at the latest, later than one year following the reception of that answer. The transferred file contains all of the documents pertaining to the file. The regulated organization remains responsible for complying with the access to information procedure.

CREATION AND CONSERVATION OF COMPLAINT FILES

A distinct file is created for each complaint established for the purposes of applying this procedure, and is kept for seven years by the person in charge.

The following information is kept with regard to each complaint:

• The name of the complainant
• The date of the complaint
• The nature of the complaint
• The name of the person that is the subject of the complaint
• The securities or services that are the subject of the complaint
• The documents examined during the investigation
• The name and position of the persons interviewed during the investigation and the dates of interviews
• The date and the conclusions of the decision made with regard to the complaint

DATE EFFECTIVE

This procedure was updated on February 1, 2010.

For the past few years, Alternative Trading Systems (“ATS”), including Alpha, Chi-X, Pure and Omega to name a few, have been operating in Canada, thus providing increased liquidity and an alternative for securities transaction turnaround. Subject to Canadian securities regulations, Laurentian Bank Securities (“LBS”) must guarantee the best price and the best execution for client orders. For this purpose, LBS uses a computerized system that provides clients with services that meet their requirements.

BEST PRICE

During regular trading hours, LBS uses a computerized system developed by the Toronto Stock Exchange to execute client orders at the best price, on one or more Canadian markets. Throughout the order routing process, LBS considers all visible markets.

MAIN MARKET

Unless otherwise indicated, LBS decided to elect the Toronto Stock Exchange (TSX) as its main market to facilitate the execution of its clients’ orders.

CANADIAN SECURITIES TRADING BUSINESS HOURS

Trading hours for most stock exchanges and ATS in Canada are 9:30 a. m. to 4:00 p.m., Eastern Standard Time (“EST”), Monday to Friday, except for official Canadian statutory holidays. Client orders made during regular business hours are entered in the order routing system and are processed based on client instructions, according to the trading hours of the market on which they are entered, to guarantee the best possible execution. Orders entered before or after regular trading hours are sent to LBS’s main market.

ORDER EXECUTION

In a multiple marketplace environment, specific order types require special processing. Unless otherwise indicated, orders will be processed according to the description provided in this document.

SPECIFIC ORDER TYPES

MARKET ORDERS

Market orders are orders to buy or sell a security at the current prevailing market price, to help ensure a complete and full execution. LBS immediately routes market orders via its computerized system, which checks every available market and books the order on the market that guarantees the best price.

LIMIT ORDERS

Limit orders are orders for a security at a minimum sale price or a maximum purchase price set by the client. When a limit order cannot be executed immediately, LBS routes it to a market that offers the best chance of execution. The order remains on the said market until it is filled, cancelled or expired. In a multiple market environment, once the order is entered on a marketplace, it is possible for the security to trade in other markets, while the client’s order remains unexecuted.

DURATION ORDERS OR GOOD-TIL-CANCELLED ORDERS

Day Orders
This type of order, which is valid for one day only, instructs the receiving market to automatically expire the order if it has not been executed in the same trading day.

Good-Til-Cancelled Orders
This type of order remains active until it is cancelled by the client or until it exceeds its set duration. The maximum duration for this type of order is 30 calendar days. Clients are responsible for monitoring the evolution of their orders and to contact their Investment Advisors to extend their orders before they expire. Orders can also have a set expiry date within the 30 day period.

Special Terms Orders
This type of order includes terms that cannot be executed in the regular marketplace. These orders will be routed to LBS’s main market. Using special terms may delay or reduce the chance that orders will be executed, and these orders are valid only during regular business hours.

Market-on-Close Orders
The “market-on-close” designation means that the whole order is to be executed at the official closing price of the marketplace it is entered upon. Not all markets support this type of order in their systems. For more details, please contact your Investment Advisor.