Target Market Determination

ABN 29 103 162 278

Australian Financial Services Licence No. 226199

Target Market Determination – Funds Management

Gleneagle Asset Management Limited –Blossom Fund

Legal disclaimer

This Target Market Determination (TMD) is required under section 994B of the Corporations Act 2001 (Cth). It sets out the target market for the product, triggers to review the target market and certain other information. It forms part of Gleneagle Asset Management Limited’s design and distribution arrangements for the product.

This document is not a product disclosure statement, and is not a summary of the product features or terms of the product. This document does not take into account any person’s individual objectives, financial situation or needs. Persons interested in acquiring this product should carefully read the Product Disclosure Statement (PDS) for Blossom Fund before making a decision whether to buy this product.

Important terms used in this TMD are defined in the TMD Definitions which supplement this document. Capitalised terms have the meaning given to them in the product’s PDS, unless otherwise defined. The PDS can be obtained by emailing BlossomApp Pty Ltd (“BlossomApp”) at blossom@blossomapp.com or by visiting our website at www.blossomapp.com.

Target Market Summary

This product is likely to be appropriate for a consumer seeking a yield from investments in fixed income products to deliver consistent income to reach consumers savings goals. It can be used as a core or satellite investment component within a portfolio or can potentially be used as a standalone investment where the consumer has a short to long investment timeframe, a moderate risk/return profile and could need daily access to capital. Consumers can set their savings goals and tracking its progress within the App and see their earnings posted daily.

Issuer	Gleneagle Asset Management Limited ("GAML")	ISIN Code	N/A
Issuer ABN	29 103 162 278	Market Identifier Code	N/A
Issuer AFSL	226199	Product Exchange Code	N/A
Fund	Blossom Fund	Date TMD approved	29/09/2021
ARSN	645 889 998	TMD Version	V.1
APIR Code	TIM3062AU	TMD Status	Current

Description of Target Market

TMD indicator key

The Consumer Attributes for which the product is likely to be appropriate have been assessed using a red/amber/green rating methodology with appropriate colour coding:

In target market

Potentially in target market

Not considered in target market

Instructions

In the tables below, Column 1, Consumer Attributes, indicates a description of the likely objectives, financial situation and needs of the class of consumers that are considering this product. Column 2, TMD indicator, indicates whether a consumer meeting the attribute in column 1 is likely to be in the target market for this product.

Generally, a consumer is unlikely to be in the target market for the product if:

one or more of their Consumer Attributes correspond to a red rating, or
three or more of their Consumer Attributes correspond to an amber rating.

Investment products and diversification

A consumer (or class of consumer) may intend to hold a product as part of a diversified portfolio (typically with an intended product use of satellite/small allocation or core component) . In such circumstances, the product should be assessed against the consumer’s attributes for the relevant portion of the portfolio, rather than the consumer’s portfolio as a whole. For example, a consumer may seek to construct a conservative portfolio with a satellite/small allocation to growth assets. In this case, it may be likely that a product with a High or Very High risk/return profile is consistent with the consumer’s objectives for that allocation notwithstanding that the risk/return profile of the consumer as a whole is Low or Medium. In making this assessment, distributors should consider all features of a product (including its key attributes).

Consumer Attributes

TMD Indicator

Product description including key attributes

Consumer's investment objective

Capital Growth

The Fund's investment objective is to deliver consistent and smoother targeted distribution of income over time through the combination of the investment strategy generating returns from more liquid segments of the fixed income market and access to the Threshold Manager.
The Fund also seeks to deliver consistent targeted income of a maximum of 4.5% calculated on the Principal per annum or an equivalent of approximately 0.008% per day (net of fees and expenses), with its commitment to environmental, social and governance (ESG) factors.
Any income distributions (if available) will be made on the last day of each financial year and will be reinvested in full unless an investor elects to receive cash distributions. Withdrawals can be made daily on any business day with a minimum of $0.01.

Capital Preservation

Capital Guaranteed

Income Distribution

Specialist (Sustainable / Ethical / Sharia / ESG)

Consumer's intended product use (% of Investable Assets)

Solution/Standalone (75-100%)

The Fund is suited to investors who are looking for:

exposure to investment grade corporate bonds with a weighted average credit weighting of the bond portfolio of no lower than BBB+, asset backed securities, inflation derivatives, interest rate derivatives, bank bills and negotiable certificates of deposit issued by larger Australian banks and other derivatives

Features:

the investment strategy targets consistent annual returns;
investors have access to Liquidity Manger's investment methodology, which is designed to produce returns and protect investors against inflation risk;
investors have access to a highly diversified portfolio of investment grade fixed income investments over the short to longer term;
asset are typically invested within the following asset allocation ranges:

Asset Class	Investment Range
Global government and corporate bonds	0% - 15%
Australian corporate bonds	0% - 100%
Australian government bonds	0% - 10%
Derivatives (exchange-traded and over the counter)	0% - 100%

Diversification:

The Fund’s portfolio comprises 20 to 70 investments. GAML believes this achieves sufficient diversification to ensure the Fund is not overly correlated to a single company, or to industry specific or macroeconomic risks.

Core Component (25-75%)

Satellite / Small allocation( < 25%)

Consumer's investment timeframe

Short ( <=2years )

The Fund is suitable for investors with short to long investment horizons.

Medium ( > 2years )

Long ( > 8years )

Consumer’s Risk (ability to bear loss) and Return profile

Low

Risk:
The Fund is suited to investors with a moderate risk profile and risk tolerance.
An investment in the Fund is subject to a number of different risks including manager skill, key person risk, credit risk, liquidity, leverage, diversification, derivatives risk, short selling risk, counterparty risk, currency risk, interest rate risk, foreign taxation, investments in other funds managed by the Liquidity Manager, fund risk, service provider risk, related party risk, legal, regulatory & tax risk, and withdrawal risk. These risks can be mitigated by the Threshold Manager or other techniques (refer to the PDS for further information).

Return:
The Fund's investment objective is to deliver consistent income and smoother targeted income over time through the combination of the investment strategy generating returns from more liquid segments of the fixed income market and access to the Threshold Manager. The Fund also seeks to deliver consistent income of a maximum of 4.5% calculated on the Principal per annum (net of fees and expenses).

Medium

High

Very High

Consumer’s need to withdraw money

Daily

An investor can withdraw all or part of their investment in the Fund at any time by making a request to withdraw a specified amount through the investor account on the App or via the Web App. The Fund generally processes redemptions on a daily basis each business day, being a day other than a Saturday, Sunday or public holiday . The Fund then generally pays the money to the investor's bank account on the following business day after the day the redemption request is processed.

There is generally a minimum withdrawal amount of $0.01 and a minimum balance of nil applies to the Fund.

In some circumstances, such as when the Fund is illiquid, investors will not be able to withdraw from the Fund, and the Fund may delay withdrawal for 21 days or more.

Weekly

Monthly

Quarterly

Annually or Longer

Appropriateness

GAML has assessed the product and formed the view that the product, including its key attributes, is likely to be consistent with the likely objectives, financial situation and needs of consumers in the target market as described above, as the features of this product in Column 3 of the table above are likely to be suitable for consumers with the attributes identified with a green TMD Indicator in Column 2.

Distribution conditions/restrictions

Distribution Condition

Distribution Condition Rationale

The Fund can be distributed to a consumer directly through GAML or indirectly through an IDPS Operator

This product is only suitable for distribution:

facilitating through Apps and the electronic platform provided by BlossomApp (appointed by GAML). GAML will process electronic application forms which are validly executed and supported by required documentation.
indirectly through an IDPS Operator who has obtained GAML's authorisation to use the Funds PDS. This authorisation process ensures that GAML has the ability to monitor and supervise the activities of any distributors of the Fund.

Each of the distribution channels for the Fund has expertise in the complex nature of the Fund and is subject to a legal requirement to provide financial services efficiently, honestly and fairly. This supports the target that the product will only be issued to investors who fall within the target market.

Review triggers This part is required under section 994B(5)(d) of the Act.
Material change to key attributes, fund investment objective and/or fees.
Material negative deviation from benchmark / objective over sustained period.
Key attributes have not performed as disclosed by a material degree and for a material period.
Determination by GAML of an ASIC reportable ‘Significant Dealing’.
Material or unexpectedly high number of complaints (as defined in section 994A(1) of the Act) about the product or distribution of the product.
The use of Product Intervention Powers, regulator orders or directions that affects the product.

Mandatory review periods This part is required under Section 994B(5)(e) and (f) of the Act.
Review Period	Maximum period for review
Initial review	1 October 2022
Subsequent review	Every 12 months

Distributor reporting requirements This part is required under section 994B(5)(g) and (h) of the Act.
Reporting requirement	Reporting period	Which distributors this requirement applies to
Complaints (as defined in section 994A(1) of the Act) relating to the product design, product availability and distribution. The distributor should provide all the content of the complaint, having regard to privacy.	Within 10 business days following end of calendar quarter.	All distributors
Significant dealing outside of target market, under s994F(6) of the Act.	As soon as practicable but no later than 10 business days after distributor becomes aware of the significant dealing.	All distributors
To the extent a distributor is aware, dealings outside the target market, including reason why acquisition is outside of target market, and whether acquisition occurred under personal advice.	Within 10 business days following end of calendar quarter.	All distributors

If practicable, distributors should adopt the FSC data standards for reports to GAML or BlossomApp. Distributors other than those appointed by GAML must report to GAML by emailing funds@gleneagle.com.au or BlossomAPP blossom@blossomapp.com This email also can be used to provide contact details relating to this TMD for GAML and BlossomApp.

Disclaimer

Issued by Gleneagle Asset Management Limited AFSL 226199 ("GAML"). GAML is the Responsible Entity and issuer of units in the managed investment scheme referred to in this material. This document does not take into account anyone’s investment objectives, financial situation or particular needs. If you are interested in acquiring this product you should carefully read and consider the PDS for the product, and consider obtaining professional investment advice tailored to your specific circumstances before making a decision whether to invest in this product. A copy of the relevant PDS relating to this product may be obtained online by emailing blossom@blossomapp.com or by visiting our website at www.blossomapp.com.

No person guarantees the future performance of the Fund, the amount or timing of any return from it, that asset allocations will be met, that it will be able to implement its investment strategy or that its investment objectives will be achieved. GAML will not be responsible or liable for any losses arising from your use or reliance upon any part of the information contained in this TMD.

Definitions

Investment objective
Term	Definition
Capital Growth	The product is designed to generate capital return from the growth of the value of the underlying assets over time. The product provides material exposure to growth assets or otherwise seeks an investment return above the current inflation rate.
Capital Preservation	The product is designed to preserve capital and limit loss in the portfolio. The product provides material exposure to defensive assets and seeks to reduce volatility and minimise loss in a market down-turn.
Capital Guaranteed	The product is designed to provide a substantially risk-free investment. The investor's invested capital is “guaranteed" against loss. The product employs a capital protection strategy (typically through investing in capital guaranteed products) or is a structured product (for example, utilises a zero coupon bond or portfolio protection insurance).
Regular Income	The product is designed to generate a positive yield in order to distribute regular investment income to investors. The product provides material exposure to income-generating assets (typically, high dividend-yielding equities, fixed income securities and money market instruments). The product may also seek long-term capital growth and be labelled with a 'total return' (or similar) strategy and objective.
Specialist (Sustainable / Ethical / Sharia / ESG)	This includes a speciality overlay, such as ESG, Sharia etc.
Product Use
Solution/Standalone (75-100%)	A solution strategy is suitable to be held as either a part or the majority (up to 100%) of the total investable assets.
Core Component (25-75%)	A core component is suitable to be held as a major component, up to 75%, of the total investable assets.
Satellite ( < 25%)	A satellite strategy is only suitable to be held as a smaller part of the total portfolio, as an indication it would be suitable for up to 25% of the total investable assets.
Investable Assets	Those assets that the investor has available for investment, excluding the family home.
Portfolio diversification
Very low	Single asset class, single country, low holdings of securities - e.g. high conviction Aussie Equities.
Low	Single Asset Class, Single Country, Moderate number of holdings, e.g. Aussie Equities Fund.
Medium	1-2 Asset Classes, Single Country, Broad exposure within asset class, e.g. Aussie Equities All Ords.
Medium High	Greater diversification across either asset classes or countries, e.g. global equities or Australian multi-asset.
High	Highly diversified across either asset classes, countries or investment managers, e.g. Australian multi-manager balanced fund or Global Equities extending beyond benchmark.
Very high	Diversified across asset classes AND across countries e.g. global multi-asset product.

Risk and Return
Issuers should undertake a comprehensive risk assessment for each product. The FSC strongly recommends adoption of the Standard Risk Measure (SRM) to calculate the likely number of negative annual returns over a 20 year period, using the guidance and methodology outlined in the Standard Risk Measure Guidance Paper For Trustees. SRM is not a complete assessment of risk. For example, it does not detail important issues such as the potential size of a negative return or that a positive return could still be less than a consumer requires to meet their investment objectives/needs. Issuers may wish to supplement the SRM methodology by also considering other risk factors. For example, some products may use leverage, derivatives or short selling, may have liquidity or withdrawal limitations, or otherwise may have a complex structure or increased investment risks, which should be documented together with the SRM to substantiate the product risk rating.
Very high risk & return	Consumer has a more aggressive or very high risk appetite, wishing to maximise returns and willing to accept higher potential losses (e.g. 6 or more negative returns over a 20 year period or SRM 7) and possibly other risk factors, such as leverage, that could increase returns, plus also the size and magnitude of losses. Consumer will typically prefer growth assets such as shares, property and alternative assets
High risk & return	Consumer will be higher risk in nature, wishing to accept higher potential losses (e.g. 4 to less than 6 negative returns over a 20 year period or SRM 6) in order to target a higher target return profile. Consumer will typically prefer predominantly growth assets such as shares, property and alternative assets with only a smaller or moderate holding in defensive assets such as cash and fixed income.
Medium risk & return	Consumer will be moderate or medium risk in nature, wishing to minimise potential losses (e.g. 1 to less than 4 negative returns over a 20 year period or SRM 3 to 5) and comfortable with a moderate target return profile. Consumer will typically prefer a balance of growth assets such as shares, property and alternative assets and defensive assets such as cash and fixed income.
Low risk & return	Consumer will be conservative or low risk in nature, wishing to minimise potential losses (e.g. less than 1 negative returns over a 20 year period or SRM 1 to 2) and comfortable with a low target return profile. Consumer will typically prefer defensive assets such as cash and fixed income.
Redemption frequency
Daily/Weekly/Monthly/Quarterly/ Annually or longer	The frequency at which redemption requests are accepted and the exit price is struck under ordinary circumstances as disclosed in the PDS, provided that the redemption request is typically paid within a reasonable period following acceptance.
Liquidity Note: Products are likely to be suitable for consumers with lower liquidity needs than the product provides (for example, a product that meets the definition of ‘High’ liquidity may be marked green for ‘Low’,‘Moderate’ and ‘High’ liquidity ratings and red for ‘Very high’.
Low	The product invests in predominantly non-exchange traded and less liquid assets, e.g. private debt or private equity.
Moderate	The product invests in a mix of liquid and less-liquid assets and typically does not meet the definition of liquid (see below).
High	The product invests in predominantly liquid assets and typically meets the definition of liquid (see below).
Very high	The product invests in entirely exchange traded or cash and cash equivalent assets that are readily realisable.
Liquid (for the purposes of the above definitions)	The product may be able to realise 80% of its assets at market value within 10 days and fall within the definition of a simple managed investment scheme.