Version 20220125
previous version 20210924
This Target Market Determination (TMD) is effective from 5 October 2021 and relates strictly to Retail Travel Insurance within the following Products Disclosure Statement and Policy Wordings:
- TRA-TWJ-AU-20220210-PDS for Travel with Jane
- TRA-TWK-AU-20220210-PDS for Travel with Kit
- TRA-TBU-AU-20220210-PDS for Travel by Us
Agile Underwriting Services Pty Ltd (ABN 48 607 908 243, AFS Licence No. 483374) (AGILE) is a coverholder at Lloyd’s and manages these Policies that are underwritten by Certain Underwriters at Lloyd’s.
About this document
This TMD identifies the customers within the target market for AGILE’s Retail Travel Insurance and provides AGILE, distributors and customers information about:
- the customers for whom this product is appropriate (being the target market);
- the customers for whom this product is NOT appropriate;
- any distribution conditions and/or restrictions attaching to the product;
- the reporting obligations of the distributors; and
- the review period(s) and events which may trigger a review.
This TMD identifies the customers within the target market for the Relevant Sections of the Product. This TMD does NOT consider a customer’s personal needs, objectives and financial situation.
Terms used in this TMD that are defined for the purpose of Chapter 7 of the Corporations Act, have the same meaning as under the Act. Please note that it is the Product Disclosure Statement that sets out the standard terms and conditions of the cover. This TMD does not form part of the terms of the cover. A customer should always refer to the relevant Product Disclosure Statement that may apply, before making a decision about this product to ensure the product is suitable for their needs.
This product has 13 sections of cover as set out below and has been designed for consumers in the target market to provide financial protection as follows:
- Overseas medical and hospital expenses
- Overseas dental expenses
- Cash in hospital
- Emergency repatriation expenses
- Overseas funeral expenses
- Emergency accommodation expenses
- Cancellation costs
- Cutting Your Trip Short
- Travel delay expenses
- Airfares for resumption of travel
- Section 11
- 11a: Personal belongings and Baggage (not including Personal Electronics)
- 11b: Personal Money
- 11c: Passport, Travel tickets, travel documents and driving license
- Legal liability
- Legal Costs
AGILE’s Retail Travel Insurance is designed to protect customers while travelling domestically and internationally against unexpected costs for specified events including cancelled flights, medical emergencies, and evacuation. The product offers options to enable customers to tailor the product to suit their individual needs.
Who is within the target market for AGILE’s Retail Travel Insurance?
Customers within the Target Market
Customers are within the target market for the Relevant Sections of this Product if all the following conditions apply.
✓ customers who are Australian citizens, or holder of a valid Australian permanent residency visa, and permanently reside in Australia;
✓ customers who hold a current Australian Medicare card (that is not a visitor Medicare card);
✓ customers who are between the ages of 18 and 69
✓ customers who require cover to manage risks arising from a single trip beginning and ending in Australia.
✓ customers who's trip is no longer than 180 days
✓ customers who have been fully vaccinated and require cover for cancellation in the event an insured person listed on the policy tests positive for Coronavirus within 14 days
✓ customers who have been fully vaccinated and require cover for medical expenses as a result of contracting Coronavirus
Customers outside the Target Market
(Customers are not within the target market if any of the following conditions apply) Note: for a comprehensive list of all exclusions within the Product please refer to the PDS.
X customers who are NOT Australian citizens, or DO NOT hold a valid Australian permanent residency visa, and DO NOT permanently reside in Australia;
X customers who DO NOT hold a current Australian Medicare card (that is not a visitor Medicare card);
X customers who are NOT between the ages of 18 and 969
X customers who DO NOT require cover to manage risks arising from a single trip beginning and ending in Australia.
X customers who require one Policy to cover multiple trips
X customers who's trip is longer than 180 days
X customers who require business travel insurance
X Customer who require a group travel policy
X customers who intend to travel to a country that the Australian Department of Foreign Affairs and Trade has, before the start date of your trip, issued a travel advisory risk rating of ‘Level 4 – Do Not Travel’ (or equivalent if the term is replaced) unless you have been issued a travel exemption by the Australian Department of Home Affairs prior to the purchase date
X customers who may not be able to travel, continue with their trip, or want to cut their trip short because any government body or local health authority closes its borders or imposes any other travel restriction in a relevant area
X customers who require cover for medical expenses whilst abroad if they have not been fully vaccinated
X customers who require cover for cancellation costs due to covid if they have not been fully vaccinated, and if they do not test positive within 14 days of departure
X customers who require cover for a pre-exisitng medical condition that is not listed as automatically covered within the PDS
Automatic Cover for certain Pre-existing Medical Conditions
The Policy provides some cover for claims relating to a number of specific Pre-existing Medical Conditions listed in the Policy if the customer has not been hospitalised for the condition in the past 36 months and any medications for the condition have remained unchanged for the past 6 months prior to taking out the Policy. Cover is not provided for any pre-existing medical condition that is not listed in the PDS.
Needs and objectives
This product has been designed for people who require a choice of different covers as set out in the table below. The crosses indicate the needs and objectives that each choice of cover has not been designed for.
Needs & objectives |
Comprehensive |
Basic |
Saver |
Domestic |
Level of cover |
High |
Mid |
Lowest |
Mid |
Are seeking cover for Financial Loss incurred as a result of overseas Medical Expenses |
✓ |
✓ |
✓ |
x |
Are seeking cover for Financial Loss incurred as a result of unforeseen Cancellations |
✓ |
✓ |
✓ |
✓ |
Are seeking cover for Financial Loss incurred as a result of delayed, lost, damaged or stolen Luggage and Personal Effects |
✓ |
✓ |
✓ |
✓ |
Are seeking cover for unexpected Financial Loss incurred as a result of Accidental Death or Disability during the trip |
✓ |
✓ |
x |
✓ |
Are seeking cover for unexpected Financial Loss incurred as a result of Legal Liability incurred during the trip |
✓ |
✓ |
✓ |
✓ |
Are seeking optional cover for Ski and Winter Sports |
✓ |
✓ |
✓ |
✓ |
Are seeking optional cover for Cruise |
x |
x |
x |
x |
Are seeking optional cover for Specified Luggage items |
✓ |
✓ |
✓ |
✓ |
How this product can be distributed and distribution conditions
The distribution conditions will make it likely that customers who acquire the insurance product are in the target market, as we consider that the distribution conditions are appropriate and will enable us and our distributors to direct the insurance product to the class of customers who fall within the target market set out above. This has been determined based on an assessment of the distribution conditions and the target market.
Distribution conditions
This product is designed to be distributed by us or our distributors by any of the following means, where authorised:
- Online through relevant websites
- By contacting the contact centre
This product can only be issued to people where they are eligible for that cover in accordance with the application and/or acceptance/renewal criteria that has been approved in writing by the issuer and which complies with relevant laws.
The purchase process has been designed to guide customers directly to the product most likely to meet their needs and objectives based on their responses to our questions.
This product can only be distributed by us or distributors where we or our distributors have received training and relevant accreditation (if required) and have met annual compliance reviews.
The agreement between the distributor and AGILE sets out the obligations to distribute products only to customers within the TMD, and the ramifications if the product is distributed to customers outside of the TMD.
The insurance product distributor must;
- be authorised to distribute the product and those arrangements must not have been cancelled or suspended;
- agree to not distribute the product where they receive notice from AGILE that this TMD is not up to date and no new TMD has been provided; and
- where a new TMD has been provided, agree to distribute in accordance with the new TMD.
The TMD is currently not subject to any ASIC action that might suggest that the TMD is no longer appropriate.
Reporting obligations
Distributors of this product are required to provide AGILE with information in relation to the product covered by this TMD in the following circumstances.
Reportable matter |
When |
The cover is issued to a customer that was ineligible for cover in accordance with the AGILE purchase process |
As soon as practicable after the Distributor becomes aware of the matter, and within 10 business days. |
Complaints information • The number of complaints the distributor has received about this product in the reporting period. • A short summary of the nature of the complaint raised and any steps taken to address the complaints; and • Any general feedback on this product. • Distributors should include sufficient details about the complaint that would allow AGILE to identify whether the TMD may no longer be appropriate to the class of customers. |
Monthly and no later than 10 business days after the agreed complaints reporting date. Notification of the complaint within 2 business days after receipt. |
There have been any significant dealings by the Distributor that are inconsistent with the TMD. |
As soon as practicable after you become aware of the matter, and within 10 business days. |
Communication from regulator in relation to the product or TMD |
Same day. |
Significant dealings
If an actual or possible significant dealing outside of the target market is identified, AGILE requires information such as the date (or date range) the dealing occurred, details about the dealing(s) and any steps or actions taken to mitigate.
Distributors should have regard to current ASIC guidelines when determining what may constitute a significant dealing.
The distributor will notify AGILE of any significant dealing in the Policy that is not consistent with the TMD as soon as practicable (within 10 business days). This includes but is not limited to a consideration of the nature and degree of harm resulting from the issue of this Product to a retail customer.
TMD reviews
Review Period
The initial review of this TMD will occur no later than 12 months from the date this TMD is first published, or within 10 business days if an event or circumstance (Review Trigger) occurs which would reasonably suggest that the TMD is no longer appropriate.
This TMD will then be reviewed at least every 24 months after the end of the previous review or agreed otherwise with AGILE.
Examples of Review Triggers that would reasonably suggest that the TMD is no longer appropriate
Outside of the identified review period this TMD may be reviewed more regularly if an event or circumstances are identified that may reasonably suggest that the product is no longer suitable to the target class of customers and would trigger a review include, but are not limited to, Product Issuer becoming aware of:
- significant increase in the number of complaints relating to the product received by us or reported by distributors;
- a material change to the product including Product Disclosure Statement, information or assumptions upon which the target market was formulated like AGILE Purchase Process, pricing requirements, underwriting guidelines;
- change of relevant law, regulatory guidance, industry code or feedback from regulators such as ASIC, APRA or other interested parties which has a material effect on the terms or distribution of the product;
- the product is being distributed and purchased in a way that is significantly inconsistent with this TMD;
- adverse trends in policy and claims data indicating the product is not performing as expected by the customer.