Optimum Asset Management Inc. commited to providing an effective and equitable system to process all complaints submitted by a person having an interest in a product or service supplied by Optimum Asset Management.

This policy on the processing of complaints explains the measures taken to enable it to respect its engagements.

COMPLIANCE MANAGER

Optimum Asset Management Inc. has appointed a Compliance Manager to establish a procedure covering the receipt of complaints, the transmission of an acknowledgment and opinions to complainants, the creation of grievance ffiles, the transmission of such files to the Autorité des marchés financiers and the compilation of complaints and transmission of a half-yearly report to the Autorité des marchés financiers.

PROCESSING OF COMPLAINTS

Any employee of Optimum Asset Management Inc. that receives a complaint must transmit it to the Compliance Manager as soon as it is received.

To quickly identify any correspondence that could be construed as a complaint, any mail received, including that marked "personal and confidential" or "in care of" is opened by a designated person before distribution. If correspondence that meets the definition of a complaint is identified, the designated person must immediately transmit it to the Compliance Manager or, in the absence of the Compliance Manager, to the President.

DEFINITION OF A COMPLAINT

For the purposes of this policy, a complaint involves at least one of the three following elements:

1. Criticism of Optimum Asset Management Inc. or one of its employees;
2. Identification of a potential or real prejudice that a client has allegedly suffered or could suffer;
3. Request for a corrective measure.

In the absence of a client complaint, any informal initiative intended to correct a specific problem is not considered a complaint, to the extent that the problem is handled as part of the day-to-day operations of Optimum Asset Management Inc.

HOW TO MAKE A COMPLAINT

In most cases, a rapid dispute-resolution is obtained by contacting your Client Relations Manager.

Should the problem is not resolved to your satisfaction, the Compliance Manager can be contacted in writing, in the following manner :

1. Briefly describe the nature of your complaint.
2. Include your name and contact information.
3. State all relevant details as well as the names of the persons with whom you have discussed the issue.
4. State the initiatives you have already taken to resolve the matter.
5. Mail the above information to the following address:

c/o Compliance Manager
Optimum Asset Management Inc.
Suite 1620
425, de Maisonneuve blvd West
Montreal, Quebec H3A 3G5

HOW YOUR COMPLAINT IS PROCESSED

Within a maximum of five (5) days following receipt of your complaint, the Compliance Manager will send you an acknowledgment.

The President and the concerned employees will be informed of your initiative.

The Compliance Manager will conduct an internal investigation to obtain as much information as possible in order to reconstruct the facts of your complaint.

We may have to communicate with you to obtain additional information or to confirm certain facts. In such circumstances, the Compliance Manager will be the person contacting you.

At any time in the process, if you are not satisfied with the handling of your complaint or the outcome of the review, you can request that a copy of your file is sent to the Autorité des marchés financiers. They may review the file and, if deemed advisable, act as mediator if the interested parties so agree.

In the 90 days following receipt of your complaint, the Compliance Manager will provide an update in the form of a written report.

COMPLAINT RESOLUTION SERVICE

If we fail to reach an agreement despite you initiatives and our co-operation. Optimum Asset Management Inc. will make available the dispute resolution service of the Autorité des marchés financiers, which will study your file and possibly recommend mediation.

Mediation is an amicable problem-resolving process. A mediator selected by the Autorité will help the complainant  to reach, if possible, a satisfactory agreement, and Optimum Asset Management Inc. will assume the costs thereof.

OTHER ALTERNATIVE

If an agreement still has not been reached after mediation, you can take your matter to the courts. It should be noted that such legal action can be lengthy, onerous and difficult. There is no guarantee that you will win your case.