Target Market Determination (TMD) – Group Active

Effective date of TMD: 17 July 2023
Version: 2.0

What’s a Target Market Determination (aka TMD)?

A TMD is a document that describes who a product is likely appropriate for (aka the target market), and any rules around how the product can be distributed. It also describes the scenarios where we may need to review this document, and reporting requirements that distributors need to follow.

This document isn’t a summary of the product and doesn’t take your personal situation into account. To learn more, read our Product Disclosure Statement (aka PDS).  You can request our PDS by sending an email to

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 features of Flip Group Active

Flip Group Active is accidental injury insurance that:

  • can be purchased by a company or individual, such as a sport event organiser, sports & recreation provider or sports organisation, to cover accidental injuries suffered by participants (the insured persons) at events or locations organised or managed by them; 
  • pays a cash benefit to an insured person if they suffer an accidental injury of a specified severity, as determined by a health professional and subject to the terms and conditions in the PDS; and 
  • only covers the insured persons for accidental injuries that happen while they are participating in an event or visiting a location covered by the Group Active policy.

Target market for Flip Group Active

This insurance is suitable for individuals or companies who are:

  • based in Australia;
  • looking for a product that will cover a group of people during an activity that carries a risk of accidental injury,  such as a sports event. 
  • looking for a product that reduces the financial impact resulting from accidental injuries to insured persons and that can be used flexibly to cover items such as medical and other expenses.
  • looking for a product that will provide a cash payout to insured persons who suffer an accidental injury of a specified severity (as determined by a health professional); and
  • looking to cover events or locations in Australia. 

This insurance is not suitable for people who are:

  • looking for a product that pays benefits to them rather than to the insured persons who participate in their events or visit their locations;
  • looking for a product that will cover injuries that happen as a result of motorcycling.

Distribution of this product

People are more likely to be in the target market if a product is distributed in line with the issuer’s distribution rules. For Flip Group Active, these rules are:

  • Applications for Flip Group Active can only be made by contacting Flip Insurance at;
  • The application process must include questions designed to determine whether  the person is likely to be in the target market; and
  • Any promotional or advertising materials must be informed by, and be consistent with, the TMD, and approved by us.

Reviewing this TMD

We will review this TMD at least every 3 years from the effective date of this TMD. We will also review this TMD earlier if a review trigger occurs that would reasonably suggest that the TMD is no longer appropriate.

Review triggers

  1. The commencement of a significant change in law that materially affects product design and/or distribution of the product or class of products that includes this product.
  2. Product performance is materially inconsistent with our expectations having regard to:
    a. Product claims ratio,
    b. The number or rate of paid, denied and withdrawn claims, or
    c. The number of policies issued, events and locations covered and insured persons.     . 
  3. 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.
  4. 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.
    *As defined in ASIC Regulatory Guide 271
  1. We determine that a significant dealing in the product outside the target market (except for an excluded dealing) has occurred.


Product performance

Distributors must report on the metrics in Review Trigger 2 on a monthly basis.


Distributors must record all complaints relating to Flip cover and must report on these  on a quarterly basis.

Distributors must report on:

  • The total number of complaints they receive during the reporting period; and
  • The nature and details of each complaint.

The reports must be shared with us within 10 business days of the end of the reporting period.

Any dealings outside the TMD

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.

HCF Life Insurance Company Pty Ltd, ABN 37 001 831 250, AFSL 236 806 is the issuer of Flip cover.