Complaints Handling

Advantage Capital Strategies. Last updated April 30, 2026

At Advantage Capital Strategies, we take every concern seriously. This policy applies to clients, employees, contractors, business partners, and members of the public. It explains how to raise a complaint or report a concern, what to expect from us, and what options are available to you if you are not satisfied with our response.

This policy is additive. ACS is a registered firm and, as such, we are subject to formal complaint handling obligations under applicable securities law, including National Instrument 31-103. Clients with complaints related to trading or advising activity should refer to the complaint process outlined in their onboarding documents, which sets out the specific procedures, timelines, and escalation rights that apply to those matters. This policy does not supersede those obligations or any other complaint channels available to you, it works alongside them.

To submit a complaint or whistleblower report under this policy, email us at info@acsgroup.ca. You are welcome to remain anonymous.

What you can report

We encourage anyone to come forward with concerns about fraud, misconduct, or unethical behaviour, breaches of securities laws or regulatory obligations, misrepresentation of investment strategies or sustainability disclosures, conflicts of interest that have not been properly disclosed or managed, and workplace misconduct or violations of our internal policies.

What to include in your complaint

The more detail you can provide, the more efficiently we can investigate. It helps to include a description of what happened and when, the names of any individuals or departments involved if known, any supporting documents or correspondence you want to share, and what resolution or outcome you are looking for. If you are submitting anonymously, include as much context as possible so we can assess the matter without needing to follow up with you.

How we handle your complaint

Once we receive your complaint, we will confirm receipt in writing within 5 business days and let you know who is handling the matter. Within 15 business days, we will determine whether it qualifies as a complaint and how it will be investigated. A fair and impartial review will then take place, thereafter. We may involve internal staff or external experts, and we will keep you updated where appropriate.

We will provide a written response summarizing our findings, our decision, and any corrective steps we are taking. If we are unable to resolve the matter in your favour, we will explain why clearly. If we cannot deliver a decision within 90 days of receiving your complaint, we will contact you to explain the delay and provide a revised timeline.

Your complaint record

For every complaint we receive, we create and maintain a record containing all relevant information and documents. You may contact us to ask about your complaint record. Records are retained in accordance with applicable securities laws, including National Instrument 31-103.

If you are not satisfied with our response

You are not required to accept our decision. If you remain dissatisfied, or if 90 days have passed without a decision, you may have the right to take your complaint to an independent third party. For complaints related to trading or advising activity, your onboarding documents outline the specific escalation rights available to you, including access to the Ombudsman for Banking Services and Investments (OBSI) at www.obsi.ca. You also have the right at any time to contact the Ontario Securities Commission (OSC) at www.osc.ca.

You always have the right to go to a lawyer or seek other ways of resolving your dispute at any time. A lawyer can advise you of your options. There are time limits for taking legal action. Delays could limit your options and legal rights later on.

Whistleblower protections

ACS has a zero-tolerance policy for retaliation against anyone who raises a concern in good faith. This applies to employees, contractors, clients, and any other person who submits a report under this policy. Retaliation includes dismissal, demotion, harassment, exclusion, loss of business, or any other adverse treatment connected to having made a report. Any employee found to have retaliated against a reporter will face disciplinary action up to and including termination of employment, and third parties who retaliate may have their relationship with ACS terminated.

All reports are treated confidentially. Information will only be disclosed to the extent necessary to conduct a proper investigation or as required by law.

Responsibilities

Our compliance team is responsible for overseeing the complaint handling process, coordinating investigations, and ensuring that regulatory reporting obligations are met.

Policy review

This policy is reviewed at least annually and updated as needed to reflect changes in regulatory requirements or our business.

Questions

Questions about this policy can be directed to info@acsgroup.ca.