Target Market Determination

WHAT IS A TARGET MARKET DETERMINATION?

This Target Market Determination (TMD) sets out the class of customers that this product has been designed for and is suitable for. It sets out the target market for the product, conditions and restrictions placed on it’s distribution, events and circumstances that would reasonably suggest that the TMD is no longer appropriate and review periods and reporting obligations for the TMD. This TMD does not provide any financial product advice on the products and does not take into consideration the objectives, financial situation and needs of individual customers. The terms and conditions of each product are set out in the Product Disclosure Statement (PDS). This TMD does not form part of the insurance contract and is not a summary of each product’s terms and conditions. Customers should review the PDS before making any decision in relation to the products. Any terms used in this TMD that are defined in the Corporations Act 2001 (Cth) have the same meaning as in that Act. This TMD is available to any person at .

EFFECTIVE DATE OF THIS TMD: 9 April 2026

ISSUER

This Target Market Determination is made by the issuer of the product. PetSure (Australia) Pty Ltd ABN 95 075 949 923, AFSL 420183 (PetSure) is the issuer of Ruff ‘n’ Tumble policies. WHO THE PRODUCT IS SUITABLE FOR: Customers whose likely needs, objectives and financial situation, are aligned with the products and their key attributes and eligibility criteria as outlined below. PRODUCT DESCRIPTION AND KEY ATTRIBUTES The products are designed for people who want cover towards eligible veterinary expenses for accidental injuries incurred by the owners of dogs. The key attributes of the products are briefly described below:  Cover is subject to an excess which applies to each accidental injury claimed, as well as terms, conditions and exclusions. Examples of key exclusions include waiting periods at the inception of a new policy and coverage exclusions for preexisting conditions.  The products do not provide cover for illness conditions like cancer or diabetes.  The products do not provide comprehensive cover for preventative care costs and general pet maintenance costs like grooming and pet food.

WHO THE PRODUCT IS SUITABLE FOR:

Customers whose likely needs, objectives and financial situation, are aligned with the products and their key attributes and eligibility criteria as outlined below.

PRODUCT DESCRIPTION AND KEY ATTRIBUTES

The products are designed for people who want cover towards eligible veterinary expenses for accidental injuries incurred by the owners of dogs. The key attributes of the products are briefly described below:

• Cover is subject to an excess which applies to each accidental injury claimed, as well as terms, conditions and exclusions. Examples of key exclusions include waiting periods at the inception of a new policy and coverage exclusions for preexisting conditions.
• The products do not provide cover for illness conditions like cancer or diabetes.
• The products do not provide comprehensive cover for preventative care costs and general pet maintenance costs like grooming and pet food.

LIKELY OBJECTIVES, FINANCIAL SITUATION AND NEEDS OF CUSTOMERS IN THE TARGET MARKET

The likely objectives, financial situation and needs of customers in the target market is a contribution towards eligible veterinary expenses that they incur, to help ensure their dog can receive appropriate treatment and to reduce (and not cover in full) the cost to the customer of that treatment. The treatment costs can vary greatly for the same condition depending on many factors including complexity of care, duration, breed, service provider, location and more. PetSure’s claims and veterinary data and experience has shown accidental injuries and illnesses can happen at any time in the life of any pet.

Customers in the target market will be able to afford to pay:

• premiums for the product, which may increase over the life of the policy;

• the full amount for treatment upfront to the veterinary clinic before seeking claims reimbursement for the eligible veterinary expenses, unless using the GapOnly® claims payment platform (in which case, customers need to be able to pay upfront the ‘gap’ payment - the ‘gap’ means the difference between the veterinary invoice for eligible expenses and the claim benefit calculated under the policy terms and conditions, if any); and
• any veterinary expenses above the accepted claim amount, including the application of the excess (where applicable);

TARGET MARKET FOR RUFF ‘n’ TUMBLE ACCIDENT INSURANCE

A person is eligible and in the target market for the product if they:

• are 18 years of age or over.
• have a domestic dog breed that is legally available in Australia.
• want cover towards the costs associated with a range of accidental injuries that their dog may experience.
• can afford to pay the applicable monthly premium, excess, upfront veterinary expenses before submitting a claim (or the ‘gap’ payment if GapOnly® is used), and/or veterinary expenses that are above the accepted claim amount.

A person will not be in the target market for the product if they:

• are seeking cover for a pet that is not a domestic dog.
• are seeking cover for pre-existing conditions.
• are seeking cover for any illnesses such as cancer, arthritis, diabetes, etc.
• are seeking full reimbursement of veterinary expenses for all accidental injuries covered.
• are seeking cover and/or full reimbursement of veterinary expenses for preventative treatments and ownership costs.
• cannot afford to pay the applicable premium, excess, upfront veterinary expenses before submitting a claim (or the ‘gap’ payment if GapOnly® is used), and/or veterinary expenses that are above the accepted claim amount (as listed above).

CONSISTENCY BETWEEN THE PRODUCTS AND THE TARGET MARKET

These products will likely meet the likely objectives, financial situation and needs of the target market because they address the needs of customers in the target market to reduce the costs of eligible veterinary expenses for accidental injuries.

DISTRIBUTION CONDITIONS

The Ruff ‘n’ Tumble product is distributed through:

• online channels including the Ruff ‘n’ Tumble website at www.ruffntumble.com.au
• the PetSure comparison tool accessible via PetSure’s website domains at www.petsure.com.au and www.gaponly.com.au
• voice channels including the contact centre of PetSure or Luna Pet Health or an authorised distribution partner.

All purchases made online use a digital purchase journey which asks the customer to answer a series of questions before finalising their purchase. Customers seeking to purchase via the phone will be asked a series of questions from a system-based script by a trained operator. The response to these questions will determine if the customer meets the eligibility criteria, which align with the description of the target market set out above. A sale will not progress if these eligibility criteria are not met. All call centre operators are provided with adequate training and their sales are routinely monitored by us to ensure that they only sell the product to customers who are in the target market.

Ruff ‘n’ Tumble policies are promoted and distributed by Luna Pet Health Pty Ltd (Luna), ABN 15 693 087 722, AR 001319575. Luna is an authorised representative of PetSure (AR no 001319575).

PetSure and Luna also in turn have arrangements with other approved distribution partners, with appropriate terms to ensure the products are distributed to the customers that fall within the target market.

PetSure will monitor whether customers are in the target market, pursuant to the criteria in this TMD. If PetSure identifies the customer is no longer in the target market, PetSure will contact the customer.

PetSure’s comparison tool provides general advice about the products and can direct the customer to the quotation tool. PetSure will monitor the comparison tool routinely.

REVIEWING THIS DOCUMENT

PetSure will review this TMD within 12 months of its effective date and subsequently at least every 24 months from the previous review.

Review Triggers

PetSure will also review this TMD if there are events or circumstances that reasonably suggest that the TMD is no longer appropriate. The triggers for this review may arise from:

• any material changes being made to the product coverage, pricing methodology, underwriting or eligibility criteria or its method of claims assessments and settlement;
• any material changes to methods of distribution;
• changes in law or regulatory guidance or industry code which may materially affect the terms of cover or distribution or regulatory feedback or concerns raised to suggest the TMD may no longer be appropriate;
• identification of systemic issues and findings, produced from quality assurance or governance processes, that may indicate an issue with the product and the appropriateness of the TMD;
• any occurrence of a significant dealing outside of the target market;
• compliance incidents and breaches that may indicate an issue with the product and the appropriateness of the TMD; or
• trends or material changes that are inconsistent with the intended product performance based on metrics that track:
  • financial performance of the product (including but not limited to the loss ratio);
  • product desirability (including but not limited to the number and types of cancellations);
  • benefit attained from the product by customers (including but not limited to the claims frequency and average benefit paid);
  • overall claims experience (including but not limited to the claims approval rates, claims processing speed and claims submission methods);
  • complaints (including but not limited to the number and type of complaints received);
  • customer feedback received (including but not limited to the number of hardship requests).

REPORTING

Distributors of these products are required to report the following information they hold to the relevant issuer within the time specified below: