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Audentium Financial Corporation adheres to the following principles. 

Principle 1 Accountability
Audentium Financial Corp. is responsible for personal information under its control and shall designate one or more persons who are accountable for Audentium Financial Corp.’s compliance with the following principles.

Principle 2 Identifying Purposes for Collection of Personal Information
Audentium Financial Corp. shall identify the purposes for which personal information is collected at or before the time the information is collected.

Principle 3 Obtaining Consent for Collection, Use or Disclosure of Personal Information
The knowledge and consent of a client or employee are required for the collection, use, or disclosure of personal information, except where inappropriate.

Principle 4 Limiting Collection of Personal Information
Audentium Financial Corp. shall limit the collection of personal information to that which is necessary for the purposes identified by Audentium Financial Corp.. Audentium Financial Corp. shall collect personal information by fair and lawful means.

Principle 5 Limiting Use, Disclosure, and Retention of Personal Information
Audentium Financial Corp. shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Audentium may be required to disclose clients’ personal information to selfregulatory organizations such as the Mutual Fund Dealers Association of Canada, Investment Dealers Association of Canada etc.

Principle 6 Accuracy of Personal Information
Personal information shall be as accurate, complete, and up to date as is necessary for the purposes for which it is to be used.

Principle 7 Security Safeguards
Audentium Financial Corp. shall protect personal information by security safeguards appropriate to the sensitivity of the information.

Principle 8 Openness Concerning Policies and Procedures
Audentium Financial Corp. shall make readily available to clients and employees specific information about its policies and procedures relating to the management of personal information.

Principle 9 Client and Employee Access to Personal Information
Audentium Financial Corp. shall inform a client or employee of the existence, use, and disclosure of his or her personal information upon request and shall give the individual access to that information. A client or employee shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Principle 10 Challenging Compliance
A client or employee shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for Audentium Financial Corp.’s compliance with Audentium Financial Corp. Privacy Code.

Summary of Complaint Handling Procedure
Audentium Financial Corp. has procedures in place to handle any written or verbal complaints received from clients in a fair and prompt manner. This is a summary of those procedures, which we provide to new clients, clients who have filed a complaint and that we also make available on our website at audentium.com.

The Client Complaint Information Form
We also provide new clients and clients who complain with separate document called the Client Complaint Information Form (“CCIF”) that provides general information about their options for making a complaint.

How to File a Complaint with Audentium Financial Corp.
Clients wishing to complain to Audentium Financial Corp. may make their complaint to our head office by contacting the compliance officer. All complaints are forwarded to qualified compliance or supervisory personnel to be handled. We encourage clients to make their complaint in writing or by email1 where possible. Where clients have difficulty putting their complaint in writing, they should advise us so that we can provide assistance. For confidentiality reasons, we will only deal with the client or another individual who has the client’s express written authorization to deal with us.

Complaint Handling Procedures
We will acknowledge receipt of complaints promptly, generally within five days. We review all complaints fairly, taking into account all relevant documents and statements obtained from the client, our records, our representative, other staff members and any other relevant source. Once our review is complete we provide clients with our response, which will be in writing if the complaint was made in writing. Our response may be an offer to resolve your complaint, a denial of the complaint with reasons or another appropriate response. Where the complaint relates to certain serious allegations2, our initial acknowledgement will include copies of this summary and the CCIF. Our response will summarize your complaint, our findings and will contain a reminder about your options with the Ombudsman for Banking Services and Investments.

We will generally provide our response within ninety days, unless we are waiting for additional information from you, or the case is novel or very complicated.

We will respond to communications you send us after the date of our response to the extent necessary to implement a resolution or to address any new issues or information you provide.

Settlements
If we offer you a financial settlement, we may ask you to sign a release and waiver for legal reasons.

Contacting Audentium Financial Corp.
Clients may contact us at any time to provide further information or to inquire as to the status of their complaint, by contacting the individual handling their complaint or by contacting the compliance officer at head office.

1 Clients who choose to communicate by email should be aware of possible confidentiality issues regarding internet communications.
2 As defined in the Policies of the Mutual Fund Dealers Association of Canada