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Complaint

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Complaint
Policy
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Summary

Emma Financial Services Inc. Policy on Complaint Processing and Dispute Resolution

Application of This Policy

This policy applies to representatives acting on behalf of Emma Financial Services Inc. Representatives who are self-employed and maintain business relationships with Emma Financial Services Inc. are responsible for managing complaints made against them and must have their own complaint processing policies. Complainants will be redirected to the relevant independent representative when applicable.

Purpose of the Policy

The purpose of a complaint processing and dispute resolution policy is to establish a fair and free procedure to handle complaints received from complainants.

It is specifically intended to govern the receipt of complaints, the sending of acknowledgments and notices to the complainant, the creation of a complaint file, the transmission of this file to the Autorité des marchés financiers (hereinafter the “Authority”), and the compilation of complaints for the purpose of preparing and submitting an annual report to the Authority.

Responsible Person

Emma has designated a person within the firm responsible for applying this policy and acting as the liaison with the Authority. This person oversees staff training and provides the necessary information to ensure compliance with this policy.

The responsible person is also tasked with:

  • Sending an acknowledgment of receipt to the complainant;
  • Sending required notices to the complainant;
  • Transmitting the file to the Authority, upon the complainant’s request;
  • Maintaining a complaint registry;
  • Submitting an annual report to the Authority.

Definition of a Complaint

For the purposes of this policy, a complaint includes at least one of the following:

  • A reproach made against a subject (e.g., representative or company);
  • The identification of a potential or actual harm suffered or that may be suffered by a consumer;
  • A demand for corrective action.

An informal step taken to resolve a specific problem is not considered a complaint if it is handled as part of the subject’s normal activities and without a formal complaint from the consumer.

Receiving a Complaint

A consumer wishing to make a complaint must do so in writing to the following address:

Emma Financial Services Inc.

Complaint processing Officer

7900 Pierre-Bertrand Blvd, Suite 300, Quebec, QC G2J 0C5

438-806-7227

plainte@emma.ca

Anyone receiving a complaint must forward it to the responsible officer immediately. The officer will acknowledge receipt within 10 business days and inform the consumer that the file will be reviewed within 90 days.

The acknowledgment will include:

  • A description of the complaint received, specifying the harm suffered or potential harm, the reproach against the subject, and the corrective action requested;
  • The name and contact information of the complaint processing officer;
  • In case of an incomplete complaint, a request for additional information required to analyze the complaint;
  • A copy of this policy;
  • A notice informing the complainant of their right to request, if dissatisfied after 90 days, that their file be transferred to the Authority, which may offer mediation if deemed appropriate and both parties agree;
  • A notice that mediation is an amicable dispute resolution process involving a third party (mediator);
  • A notice that filing a complaint with the Authority does not suspend the limitation period for taking legal action in civil courts.

Creation of a Complaint File

Each complaint must have a distinct file containing:

  • The complainant’s written complaint, including all three elements (reproach, harm, corrective measure);
  • The result of the complaint processing process (analysis and supporting documents);
  • A copy of the subject’s final, written and reasoned response sent to the complainant;
  • All documents and information relevant to the complaint.

Complaint processing

Upon receiving a complaint, an investigation must be conducted.

Each complaint must be handled fairly and impartially, with an appropriate response based on the situation.

The complaint must be processed within a reasonable time after receiving all necessary information.

The officer must then send the complainant a final written and reasoned response.

Transmission of the File to the Authority

If the complainant is not satisfied with the outcome or the process itself, they may request that their file be sent to the Autorité des marchés financiers (AMF). This right can only be exercised after the 90-day response period.

The file must include all relevant documents related to the complaint.

The subject remains responsible for protecting personal information.

Creation and Maintenance of a Registry

A complaints registry must be created for policy application purposes and updated by the complaint processing officer.

All complaints meeting the defined criteria must be registered, including:

  • Any written complaint, regardless of processing level;
  • Any legal action that meets the definition of a complaint;
  • Any complaint submitted to the Audit and Ethics Council (in the case of financial cooperatives).

Annual Report

The responsible officer submits a report to the Authority detailing the number and nature of complaints received.

For efficiency, complaints are reported once annually between March 1 and May 1, covering complaints received from January 1 to December 31 of the previous year.

Sound Complaint Management

We Act Proactively in processing Complaints

We help clients understand and properly formulate their complaints.

Once the complaint process begins, we ensure the client can obtain any information they seek regarding their complaint, including status updates.

When the Complaint Involves Another Party

If, during analysis, we determine the complaint involves another party, we:

  • Inform the client;
  • Explain how the other party is involved;
  • Provide contact details if available;
  • Encourage the client to also file their complaint with the other intermediary or insurer (without withdrawing it from our firm).

When the Complaint May Affect Other Clients

If we identify systemic issues, we take necessary steps to correct the situation for all clients affected.

We Maintain a Complaint Registry

We record complaints upon receipt in our registry. If a complaint arrives outside business hours, it is logged as soon as possible.

We ensure our leaders are informed about complaints and the follow-up actions taken, and the registry is kept up to date.

We Assign Complaints Based on Predetermined Criteria

Complaints are handled by the designated officer or someone under their supervision.

When complaints are managed by other staff, such as representatives or admin personnel, a simplified process may be used. If this process does not resolve the complaint, the responsible officer takes over to issue a final written response.

Factors influencing assignment include:

  • Complaint complexity;
  • Handler’s knowledge, training, and experience;
  • Handler’s workload.

We ensure each complaint is processed per policy and with access to necessary information.

We Take Measures to Improve Our Practices

Regular Reviews with Leadership

Quarterly, we report to leadership on:

  • Number of complaints received and responses provided;
  • Common causes and problematic patterns;
  • Challenges in implementing and adhering to the policy.

This helps identify recurring issues.

We Act to Improve

We address root causes of complaints, evaluate commonalities, understand client concerns, detect issues, and apply corrective measures.

Our Responsibilities

Representatives and Employees

Any representative or employee receiving a complaint must forward it immediately and cooperate fully, providing necessary information.

Complaint processing Personnel

A person processing complaints must remain objective and ensure they have the necessary skills. If needed, they should seek assistance and contact the client for clarification or expectations.

Our Responsibility and That of Our Leadership

We ensure all staff are aware of the policy and their roles.

We develop procedures, train complaint handlers, and designate a qualified officer. We also ensure full cooperation across the team.

Sample Acknowledgment Template

DATE

COMPLAINANT’S CONTACT INFORMATION

SUBJECT: (Complaint File Number)

Dear Sir/Madam,

We acknowledge receipt of your complaint received on [DATE]. The review of your complaint has been assigned to our Complaint processing Officer. You may contact [NAME] at the following address and phone number: [CONTACT INFO].

NOTICE

As per our complaint policy, you will receive a final written response to your complaint within [X] days. We may contact you for additional information during this period.

If you are not satisfied with our final decision or the complaint process, you may request that your file be transferred to the Autorité des marchés financiers.

The Authority will analyze your file and may offer dispute resolution services if appropriate.

Please note that transferring your file to the Authority does not stop the legal time limits (prescription) for pursuing civil legal action.

For your reference, a copy of our complaint processing policy is enclosed.

This policy was last updated on May 21, 2025

Summary of Emma Financial Services Inc.'s complaint processing and dispute resolution policy

Filing a Complaint About Our Services

We make sure complaints are assigned quickly and processed in a timely manner.

What Is a Complaint?

A complaint expresses a reproach or dissatisfaction in respect of the services or products we offer and your expectation that we take action to address the complaint.

How to File a Complaint

You can file a complaint with us by whichever means is convenient for you. We can help you file your complaint.

Contact Us

Phone: 438-806-7227

Email: plainte@emma.ca

Address: 7900 Boulevard Pierre-Bertrand, Suite 300, Quebec City, QC G2J 0C5

Our offices are open Monday to Friday from 9:00 AM to 5:00 PM.

Questions? Contact us to learn how we handle complaints.

Complaint Handling Process

1. We Acknowledge Receipt of Your Complaint

We send you a written acknowledgment within 10 days of receiving your complaint.

2. We Analyze the Complaint

We ensure we fully understand your complaint and your expectations. If needed, we will contact you to request additional information.

3. We Provide a Final Written Response

We provide you with a final written response within 90 days. In this response, we explain how we analyzed your complaint, what led to our decision, and, when possible, the solution we propose to resolve the issue.

Please contact us if you have any questions or comments about our response.

4. Evaluation of the Offer and Resolution of the Complaint

Take the time to review our response or evaluate the offer we present to resolve your complaint. In the latter case, we will give you time to confirm whether you accept our offer, reject it, or submit a counter-offer. This timeframe should be long enough to allow you to seek advice needed to make an informed decision.

5. Review of the Complaint File by the Authority

We create a file for every complaint. We retain all information and documents relevant to processing your complaint.

You may contact us to request that your complaint file be reviewed by the Authority at any time if you are dissatisfied with how we handled your complaint or with our response. We are obligated to forward your complaint file to the Authority within 15 days of your request.

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