Complaints Handling

1. General Overview

This Complaints Handling Policy of Gaulbridge Limited (“Gaulbridge”, “we”, “us”) establishes a structured and transparent framework for the acceptance, registration, management, and resolution of complaints relating to the services and products offered by Gaulbridge, as well as agreements entered into with clients.This policy is designed to ensure compliance with applicable Canadian laws and regulations, including requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), FINTRAC guidance, applicable consumer protection legislation, data protection laws, and relevant international best practices.The primary objective of this policy is to ensure a fair, effective, and transparent complaints-handling process that enhances client trust and supports regulatory compliance. Gaulbridge is committed to handling all complaints promptly, fairly, and professionally. Clients may submit complaints free of charge, and no fees are imposed for the submission, investigation, or resolution of complaints.This policy applies to all complaints received from clients or their authorised representatives relating to Gaulbridge’s services, contractual obligations, or operational matters. All employees, management, and relevant stakeholders of Gaulbridge are required to adhere to this policy to ensure a consistent and compliant approach to complaints handling.

2. Commitment to Fair and Transparent Complaints Management

Gaulbridge ensures that its complaints-handling framework reflects regulatory expectations and industry best practices, providing an impartial and structured approach to addressing client concerns.Complaints are reviewed by personnel who are independent of the subject matter and possess the appropriate knowledge and authority to ensure objective decision-making. Individuals responsible for resolving complaints are granted access to all relevant information required to conduct a thorough assessment.All complaints, along with the actions taken and outcomes reached, are documented, logged, and securely stored in accordance with record-keeping requirements. Complaint records include the nature of the issue, investigative steps, communications, and final resolution.Personal data included in complaints is processed in accordance with applicable data protection and privacy laws. Clients retain the right to request access to or correction of their personal data, subject to legal limitations.

The Compliance Officer is responsible for overseeing the effectiveness of this policy, monitoring complaint trends, and recommending enhancements where necessary. Gaulbridge reviews its complaints-handling procedures regularly to ensure continued effectiveness and regulatory alignment.Employees involved in complaints management are required to act professionally, fairly, and transparently. Appropriate training and guidance are provided, and failure to comply with this policy may result in disciplinary action.

3. Definitions

For the purposes of this policy:

Applicant means a natural or legal person submitting a complaint to Gaulbridge.

Business Day means Monday to Friday, excluding public holidays, during standard business hours.

Complaint means a written notification submitted by an Applicant alleging that their rights or interests have been adversely affected in relation to Gaulbridge’s services and requesting remediation.

Complaints Log means the internal electronic system used to record, track, and manage complaints and related information.

4. Submission of Complaints

Applicants who believe their rights or interests have been adversely affected may submit a complaint to Gaulbridge. A complaint is considered formally submitted once received through one of the approved channels below.

Complaint Submission Channels

Email: complaints@gaulbridge.com

‍Online Form: Available upon request and submitted via email

Postal Mail:
OFFICE 301
410 W GEORGIA ST
5TH FLOOR
VANCOUVER BC
V6B 1Z3
CANADA

5. Required Information for Complaint Submission

To enable efficient handling, complaints should include:

Applicant Information

Full name (individual) or legal entity nameRegistration number (for legal entities, if applicable)Residential or registered addressEmail address and telephone number

Complaint Details
‍
Date of submissionDetailed description of the issue and relevant circumstancesThe remedy or outcome sought

6. Responsibilities of the Applicant

Applicants are responsible for ensuring that all information provided is accurate and up to date. Gaulbridge will use the contact details supplied as the primary method of communication.Where a complaint is submitted by an authorised representative, appropriate documentation must be provided, including:Proof of identity of the representativeWritten authorisation or power of attorney

7. Complaint Registration and Acknowledgement

All complaints are promptly recorded in the Complaints Log upon receipt.Gaulbridge will:Acknowledge receipt of a complaint within seven (7) calendar daysProvide information regarding the handling process and indicative timelinesComplaints are generally resolved within four (4) weeks of receipt. Where additional time is required due to complexity or third-party involvement, Gaulbridge will notify the Applicant and provide status updates. Complaints will be resolved no later than eight (8) weeks from submission where reasonably practicable.

8. Complaint Log and Record Keeping

The Complaints Log includes:Applicant detailsDate and method of submissionSummary of the complaintActions taken and timelinesFinal resolution and outcomeComplaint records are retained securely for a minimum of eight (8) years following final resolution, in line with regulatory expectations and internal governance requirements.

9. Handling and Resolution of Complaints

Each complaint is assigned to a designated employee with no involvement in the matter complained of, ensuring independence and objectivity. Responses are reviewed and approved by the Compliance Officer or a delegated senior representative.Where additional information is required, Applicants may be given at least seven (7) calendar days to provide supporting documentation. Failure to provide requested information will not automatically invalidate a complaint, and Gaulbridge will proceed where possible.Where a complaint is partially or not upheld, Gaulbridge will provide:Clear reasons for the decisionAvailable escalation or alternative dispute resolution optionsInformation on relevant regulatory or legal channels

10. Complaints Involving Third Parties

Where complaints involve third-party service providers, Gaulbridge remains responsible for coordination and oversight of the resolution process.This includes:Assessing third-party involvementEngaging relevant providersKeeping the Applicant informedEnsuring appropriate corrective actionIf a complaint falls outside Gaulbridge’s responsibility and no relevant third party is involved, the Applicant will be informed and, where possible, directed to the appropriate authority.

11. Fair Treatment and Regulatory Compliance

Gaulbridge manages complaints with fairness, objectivity, and respect. Applicants are not restricted to a single submission method, and all valid complaints are considered.The policy aligns with Canadian regulatory expectations, FINTRAC guidance, and recognised international best practices.

12. Ongoing Review and Monitoring

Gaulbridge regularly reviews complaints data to identify recurring or systemic issues. This includes:Root cause analysisImplementation of corrective measuresEscalation of material issues to senior management

13. Management Oversight and Reporting

Senior management receives periodic reports on complaint trends, material issues, and remediation actions. Decisions and corrective measures are documented and retained for governance and regulatory purposes.

14. Policy Review and Updates

This Complaints Handling Policy is reviewed at least annually, or more frequently where required due to regulatory changes or operational developments. Approved updates take effect immediately and are communicated internally and, where appropriate, published on Gaulbridge’s website.