This Target Market Determination (TMD) is effective from 5 October 2021 and relates strictly to Inland Transit Insurance within the following Products Disclosure Statement and Policy Wordings:
- SPE-INL-AU-20210825-PDS for Inland Transit
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 Inland Transit 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 4 sections of cover as set out below and has been designed for consumers in the target market to provide financial protection as follows:
- Section 1: Insured Transit
- Section 2: Insured Events
- Section 3: Limitations & Exclusions
- Section 4: Claims
AGILE’s Inland Transit Insurance is designed to protect customers shipping goods within australia. It does not cover any importing or exporting activities.
Some goods cannot be covered and are excluded under this Policy. The Purchase Process lists items that are covered under “Goods that are covered” and those that are not covered under ”Goods that are NOT covered”. Customers and distributors must accept they have read and understood this list before purchasing the Policy.
Who is within the target market?
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.
✓ customers who are looking to mitigate the risk of financial loss resulting from destruction, loss or damage to their goods in transit.
✓ customers who’s goods are shipped in one continuous trip.
Customers NOT within 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
X customers who’s goods ARE NOT shipped in one continuous trip
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.
This product is designed to be distributed by us or our distributors by any of the following means, where authorised:
- Online through relevant websites
- Through licensed brokers
- 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.
Distributors of this product are required to provide AGILE with information in relation to the product covered by this TMD in the following circumstances.
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.
• 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
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.
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.