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: Nelson Cheng, Chief Executive Officer)
1090 University Avenue West
2nd Floor
Windsor, Ontario N9A 5S4
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 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.

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.

Mutual Fund Dealers Association of Canada

Client Complaint Information Form

Clients of a mutual fund dealer who are not satisfied with a financial product or service have a right to make a complaint and to seek resolution of the problem. MFDA Member dealers have a responsibility to their clients to ensure that all complaints are dealt with fairly and promptly. If you have a complaint, these are some of the steps you can take:

• Contact your mutual fund dealer. Member firms are responsible to you, the investor, for monitoring the actions of their representatives to ensure that they are in compliance with by-laws, rules and policies governing their activities. The firm will investigate any complaint that you initiate and respond back to you with the results of their investigation within the time period expected of a Member acting diligently in the circumstances, in most cases within three months of receipt of the complaint. It is helpful if your complaint is in writing.
• Contact the Mutual Fund Dealers Association of Canada ("MFDA"), which is the self-regulatory organization in Canada to which your mutual fund dealer belongs. The MFDA investigates complaints about mutual fund dealers and their representatives, and takes enforcement action where appropriate. You may make a complaint to the MFDA at any time, whether or not you have complained to your mutual fund dealer. The MFDA can be contacted:
• By completing the on-line complaint form at www.mfda.ca
• By telephone in Toronto at (416) 361-6332, or toll free at 1-888-466-6332
• By e-mail at complaints@mfda.ca **
• In writing by mail to 121 King Street West, Suite 1000, Toronto, ON M5H 3T9 or by fax at (416) 361-9073

** You may wish to consider issues of internet security when sending sensitive information by standard e-mail. **

Compensation:

The MFDA does not order compensation or restitution to clients of Members. The MFDA exists to regulate the operations, standards of practice and business conduct of its Members and their representatives with a mandate to enhance investor protection and strengthen public confidence in the Canadian mutual fund industry. If you are seeking compensation, you may consider the following:

• Ombudsman for Banking Services and Investments ("OBSI"): After the dealer's Compliance Department has responded to your complaint, you may contact OBSI. You may also contact OBSI if the dealer’s Compliance Department has not responded within 90 days of the date you complained. OBSI provides an independent and impartial process for the investigation and resolution of complaints about the provision of financial services to clients. OBSI can make a non-binding recommendation that your firm compensate you (up to $350,000) if it determines that you have been treated unfairly, taking into account the criteria of good financial services and business practice, relevant codes of practice or conduct, industry regulation and the law. The OBSI process is free of charge and is confidential. OBSI can be contacted:
• By telephone in Toronto at (416) 287-2877, or toll free at 1-888-451-4519
• By e-mail at ombudsman@obsi.ca
• Legal Assistance: You may consider retaining a lawyer to assist with the complaint. You should be aware that there are legal time limits for taking civil action. A lawyer can advise you of your options and recourses. Once the applicable limitation period expires, you may lose rights to pursue some claims.
• Manitoba, New Brunswick and Saskatchewan: Securities regulatory authorities in these provinces have the power to, in appropriate cases, order that a person or company that has contravened securities laws in their province pay compensation to a claimant. The claimant is then able to enforce such an order as if it were a judgment of the superior court in that province. For more information, please visit:
• Manitoba: www.msc.gov.mb.ca
• New Brunswick: www.nbsc-cvmnb.ca
• Saskatchewan: www.sfsc.gov.sk.ca
• Quebec: The Autorite des marches financiers ("AMF") pays indemnities to victims of fraud, fraudulent tactics or embezzlement where those responsible are individuals or firms authorized to practice under the legislation governing the provision of financial services in Quebec. It also rules on the eligibility of claims and sets the amount of the indemnities to be paid to victims. Consumers can thus be compensated to a maximum of $200,000 per claim, through funds accumulated in a financial services compensation fund. For more information, please visit www.lautorite.qc.ca.