POLICY FOR HANDLING COMPLAINTS AND DISPUTE RESOLUTION

Securities laws govern the processes by which 3D Financial Ltd. reviews and responds to client complaints. As outlined in the RDI document, clients are encouraged to contact the director in charge of compliance with any complaints. All complaints must be reported to the director in charge of compliance.

A complaint is any verbal or written statement from a client, a former client or a prospective client (Complainant), or person acting on behalf of a Complainant, alleging a grievance or dissatisfaction with any product or service offered by 3D Financial Ltd. or a representative of 3D Financial Ltd. (Complaint).

3D Financial Ltd. will document and, in a manner that a reasonable investor would consider fair and effective, respond to each Complaint made to 3D Financial Ltd.

Complaints can relate to any of the following matters:
o A breach of client confidentiality;
o Theft, fraud, misappropriation or forgery;
o Misrepresentation;
o An undisclosed or prohibited conflict of interest; or
o Personal financial dealings with a client or former client.

The director in charge of compliance may determine that a Complaint relating to matters other than those listed above are of a sufficiently serious nature to be responded to in the manner described below.

All Complaints are to be treated seriously regardless of their perceived severity or their potential indication of a violation of securities legislation.

A summary of the Policy for Handling Complaints and Dispute Resolution will be publicly available on 3D Financial Ltd.’s website and will be disseminated by any appropriate means to reach the clientele concerned.

REPORTING COMPLAINTS AND COMPLAINT REGISTER

The director in charge of compliance 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 attached as APPENDIX 12 – COMPLAINT FORM, given to the director in charge of compliance, and are entered into the Complaint Register (See APPENDIX 8 – COMPLAINT REGISTER), recording the following information:

(a) the date of the complaint;
(b) the plaintiffs name;
(c) the name of the person who is the object of the complaint;
(d) the security or services which are the object of the complaint;
(e) the date and conclusions of the decision rendered in connection with the complaint.

If the Complaint is made verbally, and is not clearly expressed, the director in charge of compliance may request that the

Complainant put the Complaint in writing in order to try and 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.

All Complaints must be acknowledged as soon as possible and reviewed in detail in a fair manner. Upon completion of the review, 3D Financial Ltd. will provide the client with a summary of the Complaint results of the investigation and an explanation of the decision. 3D Financial Ltd.’s final response concerning any Complaint will include information regarding the client’s options to escalate the Complaint, including contact information for free dispute resolution services. Clients may request that their file be transferred to the such independent service following the receipt of 3D Financial Ltd.’s final decision or the expiry of the time limit of 90 days. Any request to the independent service must be submitted no later than 180 days after the date 3D Financial Ltd. submitted the final response to the client.

ACKNOWLEDGING COMPLAINTS

Once a Complaint is received, it must be acknowledged within 10 days of receipt. The Complainant must be sent an acknowledgement that contains, at least, the following information:

(a) the name and address of the person in charge of the Complaint examination;
(b) the time allowed for examining the Complaint and subsequent communication between the
Complainant and 3D Financial Ltd.;
(c) the main elements of the Complaint examination policy;
(d) the Complaint registration date; and
(e) the Complainant’s right to have the Complaint record examined by the AMF, if dissatisfied with 3D Financial Ltd.’s processing of the Complaint or the outcome.

INVESTIGATION AND DECISION

The nature of the Complaint will determine the course, coverage and extent of the investigation.

The director in charge of compliance will review the Complaint, 3D Financial Ltd. employee statements and all supporting documentation. In the event a Complainant is dissatisfied with a decision made by 3D Financial Ltd. and requests that the Complaint be examined by the AMF, 3D Financial Ltd. will promptly provide the Complaint record to the AMF.

3D Financial Ltd. employees may not under any circumstances make private settlements with complainants.

Settlements must be approved by the director in charge of compliance and require the Complainant to sign a release prior to payment.