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Compliance & Client Care

Summary of Complaint Policy
and Dispute Resolution

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Heward Investment Management Inc. — June 2026

At Heward Investment Management Inc., we are committed to treating client concerns with fairness, diligence, and care. We have implemented a formal Complaint Handling Policy that meets the standards required by Québec's Regulation respecting complaint processing and dispute resolution and National Instrument 31-103.

How to File a Complaint

Clients may submit a complaint in writing to:

By Mail
Chief Compliance Officer
Heward Investment Management Inc.
2115 rue de la Montagne
Montreal, QC H3G 1Z8
Other Methods
Phone: 514-985-5757
Fax: 514-985-5755
Website: www.heward.com
Email: info@heward.com
Or Directly With

All complaints received verbally will be properly documented by the receiving employee and forwarded to the Chief Compliance Officer. Please let us know if you have any questions about how we process complaints.

What is a Complaint?

A complaint is any written expression of dissatisfaction regarding:

Comments, service requests, insurance claims, or corrections of clerical errors are not considered complaints under our policy.

Our Complaint Process

01

Acknowledgment

You will receive written confirmation of your complaint within 10 days, unless it is resolved more quickly through our simplified process.

02

Simplified Resolution (20 Days)

For straightforward matters that can be resolved quickly to your satisfaction, we may handle the matter informally and provide a prompt resolution.

03

Full Review

For other complaints, we will complete a thorough review and provide a final written response within 60 days (or within 90 days under exceptional circumstances).

04

Supporting You

Throughout the process, we will ensure clear communication and fair treatment. If we offer a settlement, you’ll have at least 30 days to consider it.

What You Can Expect

Our Chief Compliance Officer acts as our designated complaints officer and will be in communication with you throughout the process. Please direct all communications, questions or concerns to this person specified in the "How to File a Complaint" section.

If we cannot reach agreement or if at any point during the process you are not satisfied with how your complaint is being handled, you may ask us to transfer the file to the AMF to be examined. Heward will ensure the complaint file is transferred within 15 days of the receipt of request.

External Dispute Resolution Options

Québec Residents

You may request your file be transferred to the Autorité des marchés financiers (AMF).

The AMF may act as conciliator or mediator regarding the complaint or designate a person to act as such.

Clients Outside Québec

You may contact the Ombudsman for Banking Services and Investments (OBSI).

Available if you are not satisfied with our decision or you have not received a decision within 90 days after making a complaint and the value of the complaint is $350k or less.

These services are available at no cost and can provide independent mediation or conciliation.

Our Commitment to You

For a copy of our full Complaint Handling Policy or if you need help submitting a complaint, please contact us directly. We are here to help and take your concerns seriously.

HEWARD
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