Victim Support Cover Target Market Determination

This Target Market Determination (TMD) is made by Rape Insure Pty Ltd (ABN 62 148 903 771, AFSL 512 884), trading as rape.insure (we, us, our), as the issuer of Victim Support Cover (the product). It is made under section 994B of the Corporations Act 2001 (Cth) and forms part of the design and distribution obligations in Part 7.8A of that Act, which ASIC administers and explains in Regulatory Guide 274.

The purpose of this TMD is to describe the class of consumers for whom the product has been designed (the target market), to set the conditions and restrictions on how the product may be distributed, to identify the events and circumstances that will cause us to review it, and to specify the information distributors must report to us and when. It is written for distributors, for our own staff and for interested consumers, and is published on our website alongside the Product Disclosure Statement.

Terms used in this document

Words that are defined in the PDS have the same meaning in this TMD. In addition, the following terms are used throughout.

Distributor

Any person, other than us, who engages in retail product distribution conduct in relation to the product within the meaning of section 994A of the Corporations Act 2001, including our authorised referral partners described in section 5.

Significant dealing

A dealing in the product that is not consistent with this TMD and that is significant having regard to its nature, its scale and the potential for consumer harm. Section 8 describes the dealings we will always treat as significant.

Review trigger

An event or circumstance listed in section 6 that would reasonably suggest this TMD is no longer appropriate.

Product Governance Committee

The committee of our senior executives, chaired by our Chief Risk Officer, that approves the product, its pricing, its marketing and this TMD, and reports on product outcomes to our Board each quarter.

Application questions

Questions 1 to 5 set out in section 5, which must be asked of every consumer before cover is offered, whether the application is made online or by phone.

What the product is

Victim Support Cover is a general insurance product that pays defined benefits to an insured person who becomes the victim of a crime against the person during the period of cover. An insured event is an indictable offence against the person committed in Australia, including sexual assault and other sexual offences, assault causing injury, robbery, aggravated burglary or home invasion while an insured person was present, stalking, coercive control and family violence offences, kidnapping and threats to kill, together with the homicide of a family member of an insured person, as defined in section 4 of the PDS. Offences against property alone are not insured events. Incidents that occur overseas are covered on Premier, and on Essential and Standard where the Incidents Outside Australia option has been selected.

The product is not health insurance, life insurance, conventional income protection insurance or property insurance. It is designed to pay for the specific costs that fall to victims of crime in the weeks and months after an incident, and to pay only where Medicare, a private health fund, paid leave, workers compensation or another insurer does not.

The five benefits

Every level of cover includes all five benefits. Each benefit has its own limit, its own list of covered and excluded costs and, in one case, a waiting period, as set out in sections 6 to 10 of the PDS.

Three levels of cover

The product is offered at three levels of cover: Essential, Standard and Premier. The benefits are the same at each level. What differs is the benefit limits, the waiting period and maximum benefit period on the Income Protection and Carer Support benefit, and the services included. Base premiums start at $6.90 a week for Essential and $18.20 a week for Premier, for one adult aged 25 to 34, before optional extras, excess discount, instalment loading, GST and stamp duty.

Key attributes

The following attributes of the product are the ones most relevant to whether it is likely to be consistent with the objectives, financial situation and needs of the target market.

Who can be covered

One adult (individual), two adults living at the same address (couple), or up to two adults and their dependent children under 25 (family). The policyholder must be aged 18 or over and ordinarily resident in Australia.

Period of cover and premiums

Cover is for 12 months and is offered for renewal each year. Premiums may be paid weekly, fortnightly, monthly or annually, and an instalment loading applies to non-annual payment. The premium depends on the level of cover, who is covered, the age band of the policyholder, the state or territory of residence, any optional extras, the excess chosen and the payment frequency, plus GST and stamp duty.

Qualifying period

A 30-day qualifying period applies from the start date of a new policy. Incidents that occur before the start date or during the qualifying period are not covered. No qualifying period applies at renewal, but a new 30-day qualifying period applies to an increase in the level of cover or to an optional extra added after the policy starts, in respect of the increase only.

Waiting period

A 7-day waiting period applies to the Income Protection and Carer Support benefit on Essential and Standard. No waiting period applies on Premier, and no waiting period applies to any other benefit at any level.

Excess

The consumer chooses an excess of nil, $250 or $500 per claim at the time of purchase in return for a lower premium. No excess applies to the Forensic and Immediate Medical Costs benefit.

Optional extras

Income Protection Boost lifts income replacement, and the carer allowance, from 75% to 90% of pre-incident average weekly earnings for 18% of the base premium; the maximum weekly amount, the maximum benefit period and the benefit limit for the level of cover do not change. Incidents Outside Australia extends Essential or Standard cover to insured events that occur while an insured person is temporarily outside Australia on a trip of up to 180 consecutive days, provided their usual place of residence remains in Australia; it is included on Premier at no additional cost.

Underwriting

There are no medical questions, health checks or claims-history loadings. Cover is not available to a person who, at the time of application, has already experienced an incident, or is aware of circumstances, that could give rise to a claim.

Claims

Claims can be lodged online or by phone 24 hours a day. Emergency Relocation and Forensic and Immediate Medical Costs claims are decided within 24 hours of receiving the report reference and, on Standard and Premier, paid within 48 hours of acceptance; on Essential we aim to pay within five business days. All other decisions are made within 10 business days of receiving the information we need. One case manager is assigned for the life of the claim.

Cooling-off period

The consumer may cancel within 21 days of the start or renewal of the policy and receive a full refund of premium, provided no claim has been made.

Significant exclusions

The product does not cover loss of or damage to property, money or vehicles; death, terminal illness or total and permanent disablement; treatment that is bulk billed or paid by Medicare or a health fund; income already replaced by paid leave, workers compensation or another insurer; the cost of defending criminal charges; or incidents that occur before the start date or during the qualifying period. Section 12 of the PDS lists every general exclusion.

The product has been designed for a class of consumers who share the likely objectives, financial situation and needs described in this section. A consumer is likely to be in the target market if the description in each of the three parts applies to them. The tables that follow give practical examples of consumers who are, and are not, in the target market, and describe which level of cover is likely to suit different consumers within it.

Likely objectives

• To have money available quickly for medical, psychological, housing, income and legal costs in the weeks and months after becoming the victim of a crime, without waiting for a court process, a compensation scheme or a civil claim to resolve.
• To be able to choose their own psychologist, lawyer or other practitioner rather than relying only on public services or those appointed by a scheme.
• To protect themselves, and where relevant their partner and children, against the financial consequences of a crime against the person for a modest and predictable ongoing cost.
• To hold cover that is triggered by a report, so that they are not required to prove that anyone has been charged or convicted before they receive support.

Likely financial situation

• Able to pay the premium, from $6.90 a week for Essential cover, on an ongoing basis without financial hardship and alongside their other essential expenses.
• Would face financial strain, or would be unable to meet the cost of private treatment, an emergency move, lost income or an independent lawyer, if they had to fund those costs themselves at short notice.
• May or may not hold private health insurance, income protection through superannuation or other personal insurance. The product is designed to sit alongside those products and to pay only where they do not.
• Includes people in casual, part-time, self-employed or gig work who do not have paid leave, for whom the Income Protection and Carer Support benefit and the Income Protection Boost option are particularly relevant.

Likely needs

• Financial support that is triggered by a police report or a victim support scheme application rather than by a charge or a conviction.
• Private counselling and trauma therapy beyond the sessions funded under a Medicare Mental Health Treatment Plan, including the choice to see a particular practitioner and to include family or partner sessions.
• Fast funding for emergency accommodation, lock changes, security and relocation where the home is no longer safe.
• Replacement income, or funding for a carer, childcare and domestic help, during recovery and while attending police interviews, court hearings and medical appointments.
• Independent legal advice about the criminal justice process, victim impact statements, protection orders, victim support scheme applications and civil compensation.
• Reimbursement of the gap between Medicare and the actual cost of forensic examinations, private emergency care and specialist consultations.

Consumers who are, and are not, in the target market

The product is not designed for, and must not be distributed to, consumers described in the right-hand column. Where a consumer outside the target market approaches us or a distributor, they must be told plainly that the product is unlikely to meet their needs and, where relevant, be directed to the free support services listed on our website or to their state or territory victim support scheme.

Which level of cover is likely to suit which consumers

All three levels of cover are designed for consumers within the target market. The level that is likely to be appropriate depends mainly on the consumer's other entitlements, their income and dependants, how often they travel and what they can comfortably afford. The following table describes the consumers each level has been designed for. It is guidance for distributors and consumers; it is not a recommendation for any particular person.

Optional extras

The Income Protection Boost option is designed for consumers within the target market whose income is not otherwise protected, in particular self-employed, casual and gig workers and sole earners with dependants, who would need a higher proportion of their earnings replaced while they are unable to work. It does not extend the maximum benefit period, and it is not designed for consumers whose employer provides generous paid leave or who already hold income protection through superannuation.

The Incidents Outside Australia option is designed for consumers on Essential or Standard who travel overseas for work, study or holidays for up to 180 consecutive days at a time. It is not designed for, and does not cover, consumers who live overseas or who are outside Australia for more than 180 consecutive days in a single trip.

We have assessed the product, each level of cover and each optional extra, and have determined that the product is likely to be consistent with the likely objectives, financial situation and needs of consumers in the target market. This determination is based on the following factors.

Benefit design follows need

The five benefits correspond to the five categories of cost most often reported to us by survivors, clinicians and victim support workers during product design and in claims: medical gaps, counselling, emergency housing, lost income and independent legal help. Each benefit pays for a defined, foreseeable cost rather than an arbitrary lump sum, so the money arrives where the need is.

The trigger matches the objective

Consumers in the target market want support without waiting for the justice process. Claims are triggered by a police report or a victim support scheme application, and we never require a charge, prosecution or conviction. State and territory victim support schemes commonly take many months to determine an application and civil claims can take years; the product is designed to fill that gap.

Speed on the benefits that need it

Emergency Relocation and Forensic and Immediate Medical Costs claims are decided within 24 hours of receiving the report reference, and on Standard and Premier are paid within 48 hours of acceptance under a guarantee that pays $200 for each further day of delay, because these are the costs that arise first and cannot wait for a conventional claims cycle.

Choice of practitioner

The product funds any AHPRA-registered psychologist, clinical psychologist or psychiatrist and any Australian legal practitioner with a current practising certificate. This is consistent with the target market's need to choose who they see, and the product does not restrict consumers to a panel.

Price and structure match the financial situation

Base premiums from $6.90 a week, three levels of cover, a choice of excess and four payment frequencies allow consumers to match the cost of cover to what they can afford. There is no medical underwriting, so the price does not depend on health history, and consumers can move between levels of cover at renewal.

It sits alongside other entitlements

The product pays only where Medicare, a health fund, paid leave, workers compensation or another insurer does not. This keeps premiums modest, avoids consumers paying twice for the same cover and reflects the financial situation of the target market, most of whom hold some other entitlement.

Limits are sized to real costs

Benefit limits are set against the costs we actually see in claims. For example, the Trauma and Rehabilitation Package cap of $15,000 a year on Standard funds around 60 private sessions at typical psychologist fees, and the Emergency Relocation limit of $20,000 on Standard covers 60 nights of temporary accommodation, lock changes, removalists and a rental bond in most Australian cities.

Restrictions protect the target market

The 30-day qualifying period, the exclusion of incidents already known at the time of application and the eligibility questions in section 5 keep the product priced for unforeseen future events, which is what the target market needs it for, and prevent it being sold to people it cannot help.

Findings from our most recent review

Our periodic review of the product, completed in May 2026 and approved by the Product Governance Committee on 12 June 2026, examined claims, complaints, cancellation and distribution data for the 12 months to 31 March 2026, together with feedback from referral partners, a survey of 640 policyholders and interviews with 22 claimants. The review found that:

• of 1,184 claims lodged in the period, 93% were accepted in full or in part. The most common reason for a decline was that the incident occurred before the policy start date or during the qualifying period;
• the median time from receipt of a report reference to a decision on Emergency Relocation and Forensic and Immediate Medical Costs claims was 19 hours, and the median time to first payment was 34 hours;
• complaints about the product were 0.18% of policies in force, and no complaint referred to the Australian Financial Complaints Authority in the period was determined against us on a ground relating to product design or the target market;
• 4.1% of new policies were cancelled within the cooling-off period and 17% of policies lapsed in their first year, both within the tolerances in section 6;
• 1.3% of online applications were declined at Question 4, and the suitability check at Question 5, which was piloted from January 2026, was triggered in 2.6% of applications, of which 64% did not proceed; and
• authorised referral partners accounted for 38% of new policies, and no significant dealing was reported by, or identified in relation to, a referral partner.

These results are consistent with the product performing as designed for consumers in the target market. The review also identified a small number of consumers who had purchased Essential cover without any other income protection and whose income claims exhausted the 13-week benefit period. In response, we have strengthened the guidance in section 3 on which level of cover suits which consumers, and have made the suitability check at Question 5 a distribution condition for all channels.

The product may only be distributed through the channels, and subject to the conditions, set out in this section. These conditions are designed to make it likely that consumers who acquire the product are within the target market, and they apply in addition to any obligation a distributor has under its own licence, the Corporations Act 2001 or the General Insurance Code of Practice.

Distribution channels

Conditions applying to every channel

Personal advice

The product must not be distributed with personal advice unless the person providing the advice holds, or is an authorised representative under, an Australian financial services licence that authorises personal advice on general insurance products to retail clients, and complies with Part 7.7A of the Corporations Act 2001, including the best interests duty. We and our referral partners provide general advice only. Our staff must not recommend a level of cover, an optional extra or an excess for a particular consumer.

Application questions

Every application, whether online or by phone, must include Questions 1 to 5 in the wording we prescribe. Questions 1 to 4 are eligibility questions: if any is answered in the way indicated, cover must not be offered. Question 5 is a suitability check that must be recorded and reported to us each quarter.

Documents before purchase

The current PDS, FSG and this TMD must be made available to the consumer before cover is bound, and the consumer must confirm that they have had the opportunity to read them. The version of each document provided must be recorded against the policy.

Duty to take reasonable care

Before answering the application questions, the consumer must be told about their duty under the Insurance Contracts Act 1984 to take reasonable care not to make a misrepresentation, and why each question is asked.

Marketing and advertising

All advertising and promotional material must be approved by our Product Governance Committee before use, must be consistent with the PDS and this TMD, must carry the general advice warning and must not target consumers outside the target market. Advertising must not be placed against search terms, or in settings, that target people who are in crisis or seeking emergency help.

Consumers experiencing vulnerability

Distributors must follow our Vulnerable Customer Framework and Part 9 of the General Insurance Code of Practice. Where a consumer discloses that they are currently at risk, in crisis or have recently experienced an incident, the priority is to connect them with emergency services or a support line, not to complete a sale.

Remuneration

Our employees are not paid commission and have no sales targets. Authorised referral partners receive a referral fee of up to 5% of the first-year base premium on new policies only, as disclosed in our FSG, and no other benefit connected with sales. No inducement may be offered to a consumer to purchase the product other than the premium terms set out in the PDS.

Cooling-off and cancellation

Every consumer must be told about the 21-day cooling-off period and how to cancel, at the point of sale and again in the welcome pack, and must be given our complaints information.

Application questions

The following questions must be asked of every consumer, in this wording, before cover is offered. Questions 1 to 4 determine eligibility. Question 5 is a suitability check. Our online tool asks them automatically and will not proceed past an ineligible answer; our phone staff ask them from the call guide and record the answers against the quote.

Question 1: Age

Are you aged 18 or over? If the answer is no, cover must not be offered. A person under 18 may only be covered as a dependent child under a family policy held by a parent or guardian.

Question 2: Residence

Do you live in Australia, and do you intend to remain ordinarily resident in Australia for the next 12 months? If the answer is no, cover must not be offered.

Question 3: Who is to be covered

Is every person to be covered either you, your partner living at the same address, or your dependent child under 25? If the answer is no, cover must not be offered. The product is not available to cover friends, extended family, employees or any other person outside the policyholder's household.

Question 4: Existing incidents or circumstances

Have you, or has any person to be covered, experienced an incident, or are you aware of any circumstances, that could give rise to a claim under this policy? If the answer is yes, cover must not be offered for that person. The consumer must be given the details of the free support services we publish and, where appropriate, told about the state or territory victim support scheme that may be able to assist them.

Question 5: Purpose of cover (suitability check)

Is the main reason you are considering this cover to protect property, vehicles or money, or to replace life insurance, total and permanent disablement cover, long-term income protection or private health insurance? If the answer is yes, the consumer must be shown a clear statement that the product does not do those things and is unlikely to be right for them. The consumer may proceed only after acknowledging that statement. Every such sale must be recorded and included in the quarterly distribution data reported under section 8.

Why these conditions are appropriate

We are confident that these conditions will make it likely that the product is distributed to consumers within the target market. The product is simple, is sold only by us or on referral to us, and cannot be bound by a third party. The application questions directly test the eligibility criteria that define the target market and identify the most common mismatches between what a consumer is looking for and what the product provides. The restriction on personal advice reflects the fact that we and our partners are authorised for general advice only. The referral-only role of partners, together with the training, materials and reporting conditions, means that the organisations closest to victims of crime can point people to the product without any of the conduct risks that arise where a third party sells insurance. Our monitoring of the resulting data, described in sections 6 to 8, allows us to identify quickly if any of these assumptions no longer hold.

We will review this TMD if any of the following events or circumstances occurs, because each would reasonably suggest that the TMD is no longer appropriate. The thresholds below are the points at which a review is mandatory; the Product Governance Committee monitors the underlying data monthly and may commence a review earlier if a trend is emerging.

Where a review trigger occurs, we will commence a review as soon as practicable. If we conclude that this TMD is no longer appropriate, we will, within 10 business days of that conclusion, take reasonable steps to ensure that distributors stop distributing the product until a new TMD is made, and we will notify every distributor in writing.

Trigger 1: Material change to the product

Any change to the benefits, benefit limits, exclusions, qualifying or waiting periods, excess, pricing methodology, claims handling commitments or the terms of the PDS that could reasonably affect whether the product remains consistent with the target market, including the introduction or withdrawal of a level of cover or optional extra.

Trigger 2: Significant dealings

We become aware of a significant dealing in the product that is not consistent with this TMD, whether identified by us, reported by a distributor or raised by a consumer, ASIC or AFCA. Five or more sales in a calendar quarter to consumers who answered an eligibility question in a way that should have prevented sale is always a significant dealing.

Trigger 3: Claims experience

The accepted claims ratio for the product (claims paid and reserved as a proportion of earned premium) falls below 35% or exceeds 85% for two consecutive quarters, or the mix of claims by benefit shifts materially from the assumptions used to price the product. A low ratio may indicate that the product is not delivering value to the target market; a high ratio may indicate that it is being sold to people outside it.

Trigger 4: Claims declined or delayed

More than 15% of claims lodged in a quarter are declined in full, or more than 5% of claims are declined because the incident occurred before the start date or during the qualifying period, or the median time to first payment on Emergency Relocation claims exceeds 72 hours in any quarter.

Trigger 5: Complaints

Complaints about the product or its distribution exceed 0.5% of policies in force, or 25 complaints, in any calendar quarter; three or more complaints in a quarter raise the same design or distribution issue; or any complaint escalated to the Australian Financial Complaints Authority is determined against us on a ground relating to the design, target market or distribution of the product.

Trigger 6: Cancellations and lapses

Cancellations within the cooling-off period exceed 12% of new policies in a quarter, or first-year lapses exceed 30% of policies written in the preceding year. Either may indicate that consumers did not understand the product when they bought it or could not afford it.

Trigger 7: Regulator and external dispute resolution feedback

ASIC, APRA, the Australian Financial Complaints Authority or the General Insurance Code Governance Committee raises a concern about the product, its distribution or this TMD; ASIC issues a stop order, or exercises its product intervention power, in relation to the product or a comparable product; or we receive a notice requiring information about the product under the design and distribution obligations.

Trigger 8: Distributor conduct

A distributor breaches a distribution condition, fails to provide a report required by section 8, or has its referral agreement terminated for conduct reasons; or our monitoring identifies that a distributor is providing personal advice, using unapproved materials or targeting consumers outside the target market.

Trigger 9: Adverse media or community feedback

Sustained adverse media, social media or community commentary, or feedback from victim support organisations, clinicians or legal practitioners, that reasonably suggests the product is being sold to consumers outside the target market, is not meeting the needs of consumers within it, or is causing harm to people in crisis.

Trigger 10: Change in law or the external environment

A change in law, regulation or government policy that materially changes the needs of the target market or the value of the product, including changes to state or territory victim support schemes, the number of sessions funded under a Medicare Mental Health Treatment Plan, the Insurance Contracts Act 1984, the Privacy Act 1988, the General Insurance Code of Practice or the design and distribution obligations themselves; or a material change to our reinsurance or capital arrangements that affects the product.

We will also review this TMD if any other event or circumstance occurs that would reasonably suggest it is no longer appropriate, whether or not it is listed above.

In addition to reviews prompted by a review trigger, we review this TMD at the intervals below. The dates shown assume no earlier review; where a trigger review is completed and a new TMD is made, the periodic timetable restarts from the effective date of the new TMD.

What a review involves

Each initial and periodic review considers, at a minimum:

• claims data, including acceptance rates, reasons for decline, time to decision and payment, and the mix of claims by benefit and level of cover;
• complaints and disputes, including the outcomes of any matters referred to the Australian Financial Complaints Authority;
• sales, cancellation and lapse data by channel, level of cover and consumer characteristics, including the outcomes of the application questions;
• the reports received from distributors under section 8, and the results of our monitoring of distributor conduct;
• consumer research, including policyholder surveys and interviews with claimants and with people who chose not to proceed;
• feedback from referral partners, clinicians, legal practitioners and victim support organisations; and
• changes in law, regulation, the General Insurance Code of Practice and the wider environment in which victims of crime seek help.

The outcome of each review, and the reasons for it, are documented and approved by the Product Governance Committee and reported to our Board. Where a review results in a new TMD, the new version is published on our website at least 14 days before it takes effect, superseded versions are retained in the archive on our policy documents page, and every distributor is notified in writing.

Section 994F of the Corporations Act 2001 requires distributors to provide us with information about complaints and significant dealings, and with any other information we specify in this TMD. The obligations in this section apply to every distributor of the product, including our authorised referral partners, and apply even where the information for a period is nil. Our own sales channels report the same information internally on the same timetable.

How to report

Reports must be sent by email to distribution@rape.insure using the templates we provide. The templates are included in the distributor resource pack issued to every referral partner on appointment and are available from us on request at any time. A report is taken to have been made when we acknowledge receipt, which we will do within two business days. Where a report is urgent, in particular a significant dealing that involves a consumer who may be in crisis, the distributor should also call us on 1300 727 346 so that we can act the same day.

Complaints report template

The quarterly complaints report must contain:

• the reporting period and the date of the report;
• the name of the distributor, its ABN and, where applicable, its Australian financial services or credit licence number or referral agreement reference;
• the total number of complaints received about the product or its distribution during the period, or a statement that none were received;
• for each complaint: the date received, the channel through which it was made, a description of the complaint in the complainant's own words where possible, and its nature categorised as product design, pricing, distribution or sales conduct, claims handling, service, privacy or other;
• whether the complaint suggests that the product was acquired by a consumer outside the target market and, if so, why;
• the status of the complaint and, where resolved, the outcome and the date of resolution; and
• any general feedback received about the product, this TMD or our materials during the period.

Personal information in a complaints report must be limited to what is necessary for us to understand the complaint and identify any review trigger. The consumer's name and contact details should be included only where the consumer has agreed, or where we need them in order to resolve the complaint or remediate the consumer.

Significant dealings report template

A significant dealings report must contain:

• the date on which the dealing occurred, or the period over which it occurred, and the date on which the distributor became aware of it;
• a description of the dealing and of why it is inconsistent with this TMD;
• why the distributor considers the dealing to be significant, including the number of consumers affected, the proportion of the distributor's dealings in the product that it represents, and the actual or potential harm to consumers;
• how the dealing was identified, for example through a complaint, a review of records, a claim, or feedback from a consumer or a third party;
• the characteristics of the consumers involved that place them outside the target market;
• the steps the distributor has taken, or proposes to take, in response, including whether affected consumers have been contacted and any remediation offered; and
• the name and contact details of the person at the distributor responsible for the report.

Dealings that are always significant

Distributors must exercise their own judgement about whether a dealing is significant, but the following are always significant and must always be reported:

• any sale to a consumer who answered Question 1, 2, 3 or 4 in a way that should have prevented the sale;
• any sale that involved personal advice from a person who was not authorised to provide it;
• any sale made through a channel that is not permitted by section 5, or by a referral partner that quoted, arranged or bound cover;
• five or more sales in a calendar quarter to consumers who were flagged at Question 5;
• any dealing that ASIC, the Australian Financial Complaints Authority or a consumer has identified as inconsistent with this TMD; and
• any dealing that has resulted, or is likely to result, in a consumer suffering financial loss or being left without cover they believed they had.

Records we keep

We keep complete and accurate records of:

• this TMD and every previous version, together with the date each took effect and was superseded;
• the decisions we make in relation to this TMD, including the decision to make it, to review it, to determine that it remains appropriate and to make a new TMD, and the reasons for each decision;
• the analysis, data and consumer research relied on in each review, and the minutes of the Product Governance Committee and Board meetings at which the review was considered;
• the answers each consumer gave to the application questions and the version of the PDS, FSG and TMD provided to them;
• every complaint and significant dealing reported to us, and the steps we took in response;
• the steps we took to ensure that distribution stopped where a review trigger occurred, and the notices we sent to distributors; and
• our distributor agreements, training records and the results of our monitoring of distributor conduct.

We keep these records for at least 7 years after they are made, as required by section 994F of the Corporations Act 2001 and ASIC Regulatory Guide 274, and we make them available to ASIC on request.

Records distributors must keep

Every distributor must keep complete and accurate records of:

• the reasonable steps it has taken to ensure that its distribution of the product is consistent with this TMD, including its procedures, training and the materials it uses;
• every complaint it receives about the product or its distribution, and every significant dealing it identifies, together with the reports made to us and the dates they were sent;
• the number of consumers it referred to us in each quarter and the settings in which referrals were made;
• the version of this TMD in force at the time of each referral or dealing; and
• the completion of our annual training by each person who refers consumers to us.

Distributors must keep these records for at least 7 years after they are made, must make them available to us within 10 business days of a request, and must make them available to ASIC where required. Personal information in these records must be handled in accordance with the Privacy Act 1988 and the Australian Privacy Principles, and must be de-identified where identification is not necessary for the purpose of the record.

Our Product Governance and Distribution team is the point of contact for all matters relating to this TMD, including reports, questions about whether a particular dealing is significant, requests for approved materials and training, and notifications of a change in a distributor's circumstances.

Consumers who have a question about the product should call us on 1300 727 346 or email hello@rape.insure. Consumers who wish to make a complaint can do so using the process described in the PDS, the FSG and on our complaints page, and may refer an unresolved complaint to the Australian Financial Complaints Authority on 1800 931 678.

Related documents

• Victim Support Cover Product Disclosure Statement, VSC-PDS 3.1, effective 1 July 2026
• Financial Services Guide, RI-FSG 4.2, effective 1 July 2026
• Privacy Policy
• All policy documents and superseded versions

Version history

This TMD was approved by the Product Governance Committee of Rape Insure Pty Ltd on 12 June 2026 and takes effect on 1 July 2026. It applies to all distribution of Victim Support Cover from that date until it is replaced.