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Target Market Determination (TMD) – Group Active

Effective date of TMD: 21 June 2024
Version: 2.3

What’s a TMD?

A Target Market Determination or TMD is a document that describes which retail clients a product is likely to be appropriate for (aka the target market), and any rules around how the product can be distributed. It also describes the review and reporting processes we have in place, and reporting requirements that distributors need to follow.

This document isn’t a Product Disclosure Statement (PDS) or summary of the product terms and conditions or features of the product. It doesn’t consider customers' personal objectives, financial situation or needs. Customers should read the PDS to learn more about this product, available on the Flip website.

This TMD relates to the Flip Group Active Accidental Injury Insurance PDS dated 21 June 2024 (Flip Group Active). In this document, ‘we’, ‘us’, ‘our’ and ‘HCF Life’ means HCF Life Insurance Company Pty Ltd, AFSL 236 806. HCF Life is the issuer of Flip Group Active.

Key attributes

Scope of cover

Flip Group Active is accidental injury insurance that can be purchased by a company or individual (the policy owner) to cover participants (the insured persons) at events or locations organised or managed by the policy owner. Insured persons are automatically covered under Flip Group Active, which is taken out by the policy owner.

The scope of cover is tailored to the policy owner following the underwriting process. 

Flip Group Active pays a cash benefit to an insured person if that insured person suffers an accidental injury of a specified severity, as determined by a health professional. Benefits range from $100 to $50,000 depending on the severity of the injury.  

Flip Group Active offers an optional ambulance benefit, which pays the cost of an ambulance service up to $3,000.  The Ambulance Benefit is only available for accidental injuries while engaged in sporting activities, which are competitive or game-based sport activities involving physical exertion organised by or on the authority of the policy owner.   

The insured person can claim multiple benefits and/or accidents until they reach $50,000 in payouts.

Eligibility criteria

Applications for the product are not guaranteed to be accepted. Applications will be considered on a case-by-case basis, subject to our underwriting criteria. As part of the underwriting process for this product, customers can customise:

  • the initial period of cover; 
  • the events and locations for which accidental injuries to participants will be covered;
  • the types of participants that will be covered; 
  • the optional addition of ambulance benefit, available only for sporting activities; and
  • the premium structure. 

Cost of the product

The premium payable for the product is determined as part of the underwriting process. Premiums are payable by the policy owner, not the insured person.

Benefit limitations:

  • To be eligible for a benefit the insured person must both:
    • see a health professional within 14 days of the accident; and
    • have a health professional confirm the severity of the injury within 6 months of the accident.
  • A benefit is not payable if the insured person is eligible for a benefit for the same accidental injury under another Flip policy (other than any Ambulance Benefit, which will remain payable).
  • A benefit is not payable for any accidental injury that happens because of:
    • motorcycling;
    • taking illicit drugs or medication not as directed, or being under the influence of alcohol;
    • intentionally causing self-injury or attempting suicide; or
    • being involved in an illegal act.
  • A benefit is also not payable for any:
    • injury that results from an act of war, hostility, civil commotion, terrorism or insurrection;
    • dental injury caused by food or drink including any foreign object in the food or drink;
    • injury that happens gradually over time; or
    • injury or accident caused by a medical condition, medical episode or medical procedure or related complication.

This is only a summary of key attributes, and it does not form part of the terms for this product. Please refer to the PDS for the terms and conditions for cover, including important definitions.

Target market

Flip Group Active has been designed to be issued to individuals or companies (the policy owner) within the following target market: 

  • Eligibility: The policy owner must be based in Australia and organise events or manage locations at which individuals participate in activities which carry a risk of accidental injury. Those activities must not be primarily related to motorcycling.
  • Objectives and needs: The policy owner will want and need cover for participants at events or locations organised or managed by it, to reduce the financial impact to the participant that may arise from an accidental injury at the event or location. Individuals and companies will not be in the target market if they want or need a product that:
    • pays benefits to them rather than to the participant who sustains the accidental injury; or
    • covers all or a percentage of the actual expenses that may be incurred by an insured person as a result of an accidental injury.
  • Financial situation: The policy owner will have the capacity to pay the premium notified to it as part of the underwriting process, in accordance with the agreed premium structure, for the entirety of the initial cover period specified in the policy. 

Optional Ambulance Benefit

In addition to the target market set out above, individuals and companies will be within the target market for the Ambulance Benefit cover if they:

  • organise or authorise a sporting organisation to organise sporting activities, which are competitive or game-based sport activities involving physical exertion;
  • want or need cover for Insured Persons for the costs of ambulance services with respect to accidental injuries suffered while engaged in those sporting activities, as a participant, referee or while assisting with their conduct.

The product is likely to be consistent with the objectives, financial situation and needs of retail clients in the target market because:

  • the product will pay a cash benefit directly to participants at an event or location operated or managed by a retail client if the participant suffers an accidental injury of a specified severity, and this corresponds with the objectives and needs of retail clients in the target market; and
  • the target market is limited to retail clients who have the capacity to pay the premiums in accordance with the retail client’s chosen premium structure. If the retail client will have the capacity to pay premiums in accordance with their selected premium structure, then this is likely to be consistent with their financial situation.

Distribution conditions

Flip Group Active will be distributed solely by Flip Insurance and individual Authorised Representatives of HCF Life (Authorised Representatives) who are engaged by Flip Insurance. The following distribution conditions apply to Flip Insurance and the Authorised Representatives when engaging in retail product distribution conduct (distribution) in relation to Flip Group Active:

  • Flip Insurance must ensure that all promotional and advertising materials are consistent with the target market and that only those materials are used in relation to Flip Group Active;
  • applications for Flip Group Active are only made by contacting Flip Insurance;
  • the application and underwriting process applied by Flip Insurance must include questions designed to determine whether the person comes within the target market and tailor the scope of cover to be consistent with the individual objectives, financial situation and needs of the prospective policy owner; and
  • Authorised Representatives will:
    - only be appointed to arrange and provide general financial product advice in relation to Flip Group Active;
    - receive relevant training and be subject to appropriate oversight by Flip Insurance in relation to that appointment; and
    - have no authority to receive or process applications for Flip Group Active, to manage policies or to receive claims.

If Flip Group Active is issued to a retail client in accordance with these distribution conditions, then that retail client is likely to be in the target market for this product, because the underwriting and application process will obtain responses to questions designed to determine whether they come within the target market and include a detailed discussion with the retail client to tailor the scope of cover and premium structure to align with the retail client’s objectives, financial situation and needs.

Reviewing this TMD and reporting obligations

We will review this TMD within one year of its effective date, and then every 2 years after the first review. We will also review this TMD earlier if any of the following review triggers occurs, which reasonably suggest that the TMD is no longer appropriate:

Review trigger explanation Obligations
1. Regulatory environment The commencement of a significant change in law that materially affects the product design or distribution of this product. We must monitor relevant regulation, legislation and/or ASIC instruments relating to the change in law, as required.
2. Product performance Product performance is materially inconsistent with our expectations having regard to:
– the number of policies sold;
– policy lapse and cancellation rates;
– the product claims ratio;
– the number or rate of paid, denied and withdrawn claims;
– the scope of the policies issued, the events and locations covered and the scope of insured persons.		 We must monitor product performance metrics on a quarterly basis against targets and expectations.
Flip Insurance must report on these metrics on a monthly basis. This information must be shared with us within 10 business days of the end of the reporting period.
3. Product changes Material changes in the product design or distribution which in our view could change:
– the target market; or
– the distribution conditions which will make the product more likely to be issued to customers who are within the target market.		 We must assess changes to product terms or distribution to determine if they trigger a review.
4. Product intervention powers ASIC’s use of its Product Intervention Powers in relation to the distribution or design of this product where we consider this reasonably suggests that this TMD is no longer appropriate. We must monitor the terms of any Product Intervention Order made or proposed to be made by ASIC which affects the product, as required.
5. Complaints Significant or unexpectedly high number of complaints regarding product design, claims, or distribution where we consider that this reasonably suggests that the TMD is no longer appropriate. Flip Insurance and Authorised Representatives must record all complaints relating to Flip Group Active cover and must report the following to us on a monthly basis.
Distributors must report on:
– the total number of complaints they received during the reporting period; and
– the nature and details of each complaint.
This information must be shared with us within 10 business days of the end of the reporting period.
6. Significant dealings We determine that a significant dealing in the product outside the target market (except for an excluded dealing) has occurred. Any dealing in the product to a person which we, Flip Insurance or the Authorised Representatives, become aware is not consistent with the TMD must be reported to us within 10 business days of becoming aware of the dealing.

Previous Group Active TMDs