Sterling's Assurance

Client Complaint Procedures

Sterling Mutuals Inc. ("Sterling") takes client complaints, written or verbal, very seriously. If you have concerns regarding your account(s), your Sterling Advisor and/or one of our staff, we have developed the following detailed complaint procedures in order for us to address your concerns in a timely manner.

Step 1 - Submission of Your Complaint

When submitting a complaint, written or verbal, to Sterling it is important to include a few important items regarding your account information such as:

• Name of your Sterling Advisor or name of applicable Staff
• Your account number(s)
• The details of your complaint and all applicable supporting documentation
• Your contact information

You can submit your complaint:

• Via mail Sterling Mutuals Inc. (Attention: Som Houmphanh, Chief Compliance Officer)
  1090 University Ave. West
  2nd Floor
  Windsor, Ontario
• Via email complaints@sterlingmutuals.com
• Via fax 519-256-9730
• Via phone 1-800-354-4956

Step 2 - Acknowledgement of Your Complaint

Upon receiving your written or verbal complaint, Sterling will issue a letter to you acknowledging receipt within 5 business days. This Acknowledgement Letter will provide a summary of our investigation procedures and the name and contact information of the senior Compliance person assigned to investigate your concerns and will include an industry brochure that outlines alternate methods of dispute resolution available to you.

Step 3 - Handling of Complaints

Our internal complaint handling process includes a thorough review of your complaint including reviewing all relevant supporting documentation, meeting notes and logs, and may also include an interview with you and the advisor/staff member to determine if any breach of internal or regulatory policies occurred. This review will be conducted by an appropriately qualified member of our Compliance team and may take up to 90 days to complete. If we are unable to respond within the 90 day period, we will inform you of the reason for the delay and provide an estimated timeframe for when you can expect a response.

Step 4 - Release of Our Findings

Upon completion of our review, Sterling will release to you a detailed substantive response letter of our findings. As required by industry regulators, our response will be released within 90 calendar days after receipt of the complaint which may include an offer to resolve or deny your complaint with reasons. You will be provided an industry brochure with our substantive response letter that outlines alternate methods of dispute resolution available to you if you are not satisfied with our response. If a delay occurs and we are not able to provide a substantive response within 90 days, we will provide you with a written explanation for the delay and an expected date of completion.