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Target Market Determination (TMD) – Group Active

Effective date of TMD: 25 August 2023
Version: 2.1

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 your personal objectives, financial situation or needs. To learn more about this product, read the PDS.  You can request our PDS via email to partnerships@getflip.com.au

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 cover. 

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.  

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; 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. 
  • 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 for individuals or companies based in Australia who organise or manage events or locations with the following objectives, financial situations and needs: 

  • Eligibility: Willing to go through the underwriting process and able to obtain insurance through this product based on our underwriting criteria.
  • Objectives: Looking to reduce, for participants at events or locations organised or managed by the policy owner, the financial impact to the participant that may arise from an accidental injury at the event or location. 
  • Financial situation: Have the capacity to pay the premium notified to the policy owner as part of the underwriting process, in accordance with the premium structure selected by and agreed with the policy owner, for the entirety of the initial cover period specified in the policy. 
  • Needs: Requires a policy that will provide financial support in the form of a cash benefit to participants in the event of an accidental injury at events or locations organised or managed by the policy owner.

This insurance is not suitable for people who are:

  • looking for a product that pays benefits to them (the policy owner) rather than to the participant who sustains the accidental injury; or
  • looking for a product that covers all or a percentage of the actual expenses that may be incurred by an insured person as a result of an accidental injury.

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

Any person who engages in retail product distribution conduct (distribution) in relation to this product must comply with the following requirements:

  • any promotional or advertising materials must be approved by us as consistent with the target market;
  • applications for Flip Group Active can be made only by contacting Flip Insurance at partnerships@getflip.com; and
  • the application and underwriting process must include questions designed to tailor the scope of cover to be consistent with the objectives, financial situation and needs of the prospective policy owner.

If the product 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 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 a review trigger occurs.

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; or
– the average claims duration.		 We must monitor product performance metrics on a quarterly basis against targets and expectations.
Distributors 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. Distributors must record all complaints relating to Flip cover and must report the following to us on a quarterly 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 and/or our distributors 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