Target Market Determination.

1. About this document

This Target Market Determination (TMD) describes the class of consumers for whom the Benefund service is likely to be appropriate, the conditions on its distribution, and the circumstances in which the TMD must be reviewed. It is prepared in accordance with Part 7.8A of the Corporations Act 2001 (Cth).

This document is not a substitute for our Disclosure Statement. You should read both before deciding whether to use Benefund.

2. The product

The Benefund service is a managed investment offering that allows individuals to contribute funds, have those funds invested under three published strategies (Conservative, Balanced, Growth), and have a configurable percentage (75–100%) of investment yield distributed quarterly to charities the member selects. Member principal is preserved and continues to be invested.

3. The target market

Benefund is designed for Australian retail consumers who:

• Are aged 18 or over and Australian residents.
• Have a primary objective of supporting charitable causes through ongoing, structured giving.
• Wish to commit funds for long-term charitable purposes rather than for personal wealth accumulation, retirement, or short-term savings.
• Have an investment horizon of at least 3 years (Conservative), 5 years (Balanced), or 7 years (Growth).
• Can tolerate the level of investment risk associated with their chosen strategy.
• Understand that returns are not guaranteed and capital values will fluctuate.
• Have other financial resources sufficient to meet their personal financial needs (e.g. emergency savings, housing, retirement) without reliance on funds contributed to Benefund.

4. Who Benefund is NOT designed for

Benefund is unlikely to be appropriate for consumers who:

• Need access to their funds for short-term consumption, emergencies, or other personal expenses.
• Are seeking primarily to grow personal wealth or build retirement savings (a regulated superannuation fund or other appropriate product would better suit these needs).
• Are looking for a guaranteed-return savings or term deposit product.
• Are unable to tolerate any decline in capital value during periods of market volatility.
• Do not have other financial resources sufficient to meet their day-to-day and emergency needs.
• Are minors, non-residents, or do not have legal capacity to enter into financial agreements.

5. Distribution conditions

The Benefund service will be distributed through:

• Direct online onboarding via app.benefund.com.au.
• Workplace partnerships with employers under separate Employer Agreements that require employees to opt in voluntarily.

We do not distribute through commission-based intermediaries, financial advisers paid by Benefund, or unregulated third-party channels. We do not engage in unsolicited cold outreach to consumers.

Marketing communications will not target consumers outside the target market described above. Onboarding screens and our calculator make clear that Benefund is a charitable giving product, not a wealth-building or retirement product.

6. Investment strategy alignment

Each investment strategy is designed for a sub-segment of the target market:

• Conservative — for consumers with a horizon of 3+ years and lower risk tolerance.
• Balanced — for consumers with a horizon of 5+ years and medium risk tolerance.
• Growth — for consumers with a horizon of 7+ years and higher risk tolerance.

Members are guided through a strategy selection during onboarding that surfaces the indicative volatility, return profile, and recommended horizon for each strategy.

7. Reporting and review triggers

This TMD will be reviewed at least annually, and earlier if any of the following triggers occur:

• A material change to the product features, fees, or risk profile.
• A material change to applicable laws, regulations, or regulator guidance.
• Significant or systemic dealings outside the target market identified by us, our employer partners, or regulators.
• Member complaints that indicate the product is being acquired by consumers outside the target market.
• A significant proportion of members closing their accounts within 12 months of opening.

8. Reporting obligations

Benefund and its distributors are required to report:

• Significant dealings outside the target market — to ASIC within 10 business days of becoming aware.
• Complaints relating to the product — to Benefund quarterly.
• Information about the design or distribution of the product that would reasonably be expected to be needed to determine whether to review the TMD — to Benefund as soon as reasonably practicable.

9. Contact

For questions about this Target Market Determination, please contact us at hello@benefund.com.au.