This TMD is prepared to meet Design and Distribution Obligations (Part 7.8A) of the Corporations Act 2001 (Cth). It is not a disclosure document or financial advice. Customers must read the HeroClear Terms and the Employment Hero Platform Terms and Conditions.

Target Market Determination
Product	HeroClear (Beta) Non‑cash payment facility for superannuation contributions
Issuer	Employment Hero Pty Ltd (ABN 11 160 047 709) (Employment Hero, EH, we/us/our)
Start Date	November 2025
Version	1.0 – This TMD applies to HeroClear during the beta period. We will review and update this TMD before or at General Availability (GA).
Review Date	May 2026 or GA, whichever is earlier
Target market	This product is intended for Australian employer entities (with ABN/ACN) that: – use (or intend to use) the Employment Hero platform for payroll/HR; – seek to initiate superannuation contribution payments in batches and transmit SuperStream messages; – are able to confirm the debit amount and source account/channel for each Contribution Cycle; and – have operational capability to manage approvals, cut‑offs, reconciliation and error remediation. This product is not intended for:  – individuals/consumers or non‑business users; – employers requiring financial product advice or guaranteed settlement times; – employers unable to maintain sufficient cleared funds, accurate data or timely approvals; and – scenarios where EH is expected to act as a super fund, trustee, adviser or custodian. Having assessed the product’s attributes (next section), EH considers the product likely to be consistent with the likely objectives, financial situation and needs of the target market described above.
Product attributes	The product is a non‑cash payment facility issued by us, that lets you initiate payments for employer superannuation contributions and sends SuperStream messages to nominated funds.  We create and manage PayTo mandates and BECS can be enabled as a fallback only if you’ve signed a DDRSA/DDR. Each Contribution Cycle requires you to confirm the total amount and source account/channel. We don’t use standing authorities. After confirmation, the platform initiates debits to fund the authorised batch of super contributions and we prepare and transmit SuperStream messages linked to the matching payment. Access can depend on the availability of the NPP/PayTo sponsor bank, BECS processor (if used), and messaging gateway; correct employer data; bank/fund cut‑offs. There are payment processing and messaging limitations: – Timing from debit to fund receipt is variable and contributions are treated as paid only on fund receipt; – During processing, funds may be held in an EH settlement account and EH retains interest on balances in transit; – External dependencies (banks, PayTo/BECS rails, SuperStream gateways) can affect availability and speed; and – Failed debits and data mismatches can trigger returns, requiring correction and resubmission. Our fees are set out in the HeroClear Terms.
Appropriate Statement	We have considered the product is likely to be consistent with the possible objectives, financial situation and needs of the Target Market because it enables integrated initiation of super contribution payments with linked SuperStream messaging, requires per-cycle approval, supports operational visibility and exception handling, and assumes access to a suitable Australian business bank account and tolerance for indicative (not guaranteed) settlement timing.
Distribution conditions & restrictions	The product is enabled only within the EH Platform, and it is not distributed or sold through off-platform channels. For the purposes of this TMD, Employment Hero is the sole distributor of the product. Access is limited to Australian employer entities with an ABN/ACN that accept the HeroClear Terms and General Terms and complete any required verification (including, KYB). Customers must maintain a supported Australian business bank account and, if they wish to use BECS, they must execute the DDRSA/DDR before it’s enabled. At the point of enablement and before each Contribution Cycle, the platform requires per-cycle confirmation of the total debit amount and the source account/channel, and it presents disclosures that contributions are only counted as paid when the destination fund receives them. The product is not distributed to individuals/consumers, it does not provide financial product advice, and it does not guarantee settlement times.
Review triggers & review periods	We will do an initial review of this TMD within six months of first issue or at General Availability (GA) launch, whichever occurs first, with periodic reviews at least every twelve months thereafter. We will otherwise review the TMD if any of the following triggers occur: – a material change to PayTo/NPP, BECS, or SuperStream rules or standards that affects product attributes; – a material change to the product attributes, design, fees, charges, terms or conditions; – any significant dealing that is not consistent with the target market or this TMD; or  – material complaints (in number or significance) relate to complaints concerning the terms of this product and or the distribution conduct.
Reporting requirements (for distributors)	The distributor of the product must provide the following information to us, within the below timeframes: – a monthly complaints report within 10 business days of month-end; any significant dealing outside the Target Market as soon as practicable and within 10 business days; – a monthly summary of payment failures, returns and SuperStream rejects by root cause; and – any out-of-market enablements within 5 business days of discovery. Distributors must escalate regulatory inquiries within 2 business days and send all reports in writing. Where we are the sole distributor, we will generate and retain these reports.
Record‑keeping & availability	We will maintain records of this TMD, all reviews, distribution information, significant dealings and complaints per our retention policy. We will publish the current TMD on our website and make it available in-platform. We will version-stamp the TMD and record key dates.  We will retain evidence of eligibility gates, point-of-sale controls and audit trails to demonstrate DDO compliance. Any distributor must keep equivalent records and provide them to us on request.