Target Market
Determination

Betashares Energy Transition Metals ETF
ASX: XMET
Legal disclaimer
This Target Market Determination (TMD) is required under section 994B of the Corporations Act 2001 (Cth) (the Act).

This TMD describes the class of consumers that comprises the target market for the financial product and matters relevant to the product’s distribution and review(specifically, distribution conditions, review triggers and periods, and reporting requirements). Distributors must take reasonable steps that will, or are reasonably likely
to, result in distribution of the product being consistent with the most recent TMD (unless the distribution is excluded conduct).
This document is not a product disclosure statement (PDS) and is not a complete 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 PDS for the productbefore 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 at www.betashares.com.au or by calling 1300 487 577.

Target market summary
This product is intended for use as a satellite component of a broader global equities allocation for a consumer who is seeking capital growth and has a very highrisk and return profile for that portion of their investment portfolio. It is likely to be consistent with the financial situation and needs of a consumer with a minimum
investment timeframe of 5 years or more, and who needs to withdraw their money on less than one week’s notice.
The Fund is an exchange-traded product and is generally only available to consumers through the ASX.

1TARGET MARKET DETERMINATION | Betashares Energy Transition Metals ETF ASX: XMETFund and issuer identifiersIssuerBetashares Capital Limited

Issuer ABN

78 139 566 868

Issuer AFSL

341181Fund manager
Fund name
ARSN

Betashares Capital Limited

657 340 371
N/A

ISIN code

AU0000237406

Market identifier code

XASX

Product exchange code

ASX: XMETTMD issue date

TMD indicator key
The Consumer Attributes for which the product is likely to be appropriate havebeen assessed using a red/green rating methodology with appropriate colour
coding:In Target Market

Not in Target Market

Betashares Energy Transition Metals ETF

APIR code

TMD contact details

Description of 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.

DDO.Reporting@betashares.com.au
05 December 2023

TMD version

2

Distribution status of fundA

Appropriateness
The Issuer 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 situationand needs of consumers in the target market, as the features of this product in Column 3 of the table below are likely to be suitable for consumers with the attributes
identified with a green TMD Indicator in Column 2.

2

TARGET MARKET DETERMINATION | Betashares Energy Transition Metals ETF ASX: XMETInvestment products and diversification
A consumer (or class of consumer) may intend to hold a product as part of a diversified portfolio (for example, with an intended product use of minor allocation). In suchcircumstances, 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 balanced or moderate diversified portfolio with a minor allocation to growth assets. In this case, a product with a Highrisk/return profile may be consistent with the consumer’s objectives for that minor allocation notwithstanding that the risk/return profile of the consumer as a whole isMedium. In making this assessment, distributors should consider all features of a product (including its key attributes).
The FSC has provided more detailed guidance on how to take this portfolio view for diversification, available on the FSC website.

Consumer attributes

TMD indicator

Product description including key attributes

In target market

The Fund aims to track the performance of an index (before fees and expenses) that provides exposure to listedcompanies in the global ETMs industry.

Capital Preservation

Not in target market

ETMs are metals and raw materials that are essential to the transition to a less carbon intensive economy. These
include copper, lithium, nickel, cobalt, graphite, manganese, rare earths, and silver.

Income Distribution

Not in target market

Capital Growth: The Fund is intended for use by investors who are seeking capital growth from exposure to listedcompanies in the global ETMs industry.

Consumer’s investment objective
Capital Growth

3

TARGET MARKET DETERMINATION | Betashares Energy Transition Metals ETF ASX: XMETInvestment products and diversification
Consumer attributes

TMD indicator

Product description including key attributes

Consumer’s intended product use (% of Investable Assets)
Solution/Standalone (up to 100%)

Not in target market

Major allocation (up to 75%)

Not in target market
The Fund may be used as a satellite component of a broader global equities allocation.

Core component (up to 50%)

Not in target market

Minor allocation (up to 25%)

Not in target market

Satellite allocation (up to 10%)

In target market

The Fund itself has low portfolio diversification as it provides exposure to approximately 35 holdings with involvement in the ETMs industry.

Consumer’s investment timeframe
A minimum investment timeframe of 5 years or more is suggested.
Minimum investment timeframe

4

5 years or more

The Fund may also potentially be considered for a tactical allocation over a shorter investment timeframe, thoughsuch use would involve higher risk of capital loss as the investment in the Fund would be held for a period lessthan the suggested minimum investment timeframe.

TARGET MARKET DETERMINATION | Betashares Energy Transition Metals ETF ASX: XMETInvestment products and diversification
Consumer attributes

TMD indicator

Product description including key attributes

Consumer’s risk (ability to bear loss) and return profile
Low

Not in target market

MediumNot in target marketHigh

Not in target market

Very High

Extremely HighIn target market

An investment in the Fund is very high risk in nature (SRM 7).
In particular, for the relevant part of the consumer’s portfolio, the consumer:•has a very high risk appetite,•can accept very high volatility and potential losses (e.g. has the ability to bear 6 to 7 negative returns over a 20
year period (SRM 6 or 7),•seeks to maximise returns (typically over a medium or long timeframe).

Not in target market

Consumer’s need to access capital

5

Within one week of request

In target market

Within one month of request

In target market

Within three months of request

In target market

Within one year of request

In target market

Within five years of request

In target market

Within 10 years of request

In target market

Ten years or more

In target market

As the Fund is exchange traded, under ordinary circumstances investors are able to buy and sell units in the Fundduring ASX trading hours according to a T+2 settlement cycle.
Though market making arrangements are in place to assist in maintaining liquidity for the Fund’s units, market
making may not be available in certain circumstances, e.g. due to operational or market disruptions. In such circumstances, investors may temporarily be subject to increased bid-offer spreads for units or be unable able to buy
and sell units in the Fund.
Units in the Fund may be suspended from trading in exceptional circumstances, e.g. if the responsible entity
suspends the issue or withdrawal of units in accordance with the Fund constitution, acting in the best interests ofinvestors.

TARGET MARKET DETERMINATION | Betashares Energy Transition Metals ETF ASX: XMETDistribution conditions/restrictions
Distribution condition
There are no distribution conditions.

Distribution condition rationale

Distributors this condition
applies to

Not Applicable

All distributors

Review triggers
Material change to key attributes, fund investment objective and/or fees.
Material 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 the issuer 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.

6

TARGET MARKET DETERMINATION | Betashares Energy Transition Metals ETF ASX: XMETDistribution conditions/restrictions
Mandatory TMD review periods
Review period

Maximum period for review

Initial review

1 years and 3 months

Subsequent review

1 years and 3 months

Distributor reporting requirements
Reporting requirement

Reporting period

Which distributors this requirement
applies toComplaints (as defined in section 994A(1) of the Act) relating to the
product. The distributor should provide all the content of the complaint,
having regard to privacy.

As soon as practicable but no later than 10 business days
following end of calendar quarter.

All distributors

Significant dealing outside of target market, under section 994F(6) of theAct. See Definitions for further detail.

As soon as practicable but no later than 10 business days after
distributor becomes aware of the significant dealing.

All distributors

If practicable, distributors should adopt the FSC data standards for reports to the issuer. Distributors must report to Betashares by sending reports by email to DDO.
Reporting@betashares.com.au or as otherwise agreed.

7

TARGET MARKET DETERMINATION | Betashares Energy Transition Metals ETF ASX: XMETDefinitions
In some instances, examples have been provided below. These examples are indicative only and not exhaustive.
Term

Definition

Consumer’s investment objective
Capital Growth

The consumer seeks to invest in a product designed or expected to generate capital return over the investment timeframe. The consumer prefers
exposure to growth assets (such as shares or property) or otherwise seeks an investment return above the current inflation rate.

Capital Preservation

The consumer seeks to invest in a product designed or expected to have low volatility and minimise capital loss. The consumer prefers exposure to
defensive assets that are generally lower in risk and less volatile than growth investments (this may include cash or fixed income securities).

Income Distribution

The consumer seeks to invest in a product designed or expected to distribute regular and/or tax-effective income. The consumer prefers exposure
to income-generating assets (this may include high dividend-yielding equities, fixed income securities and money market instruments).

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

8

Solution/Standalone (up to 100%)

The consumer may hold the investment as up to 100% of their total investable assets.
The consumer is likely to seek a product with at least very high portfolio diversification.

Major allocation (up to 75%)

The consumer may hold the investment as up to 75% of their total investable assets.
The consumer is likely to seek a product with at least high portfolio diversification.

Core component (up to 50%)

The consumer may hold the investment as up to 50% of their total investable assets.
The consumer is likely to seek a product with at least medium portfolio diversification.

Minor allocation (up to 25%)

The consumer may hold the investment as up to 25% of their total investable assets.
The consumer is likely to seek a product with at least low portfolio diversification.

Satellite (up to 10%)The consumer may hold the investment as up to 10% of the total investable assets.
The consumer may seek a product with very low portfolio diversification.
Products classified as extremely high risk are likely to meet this category only.

Investable Assets

Those assets that the investor has available for investment, excluding the residential home.

TARGET MARKET DETERMINATION | Betashares Energy Transition Metals ETF ASX: XMETDefinitions
Term

Definition

Portfolio diversification (for completing the key product attribute section of consumer’s intended product use)
Note: exposures to cash and cash-like instruments may sit outside the diversification framework below.
Very low

The product provides exposure to a single asset (for example, a commercial property) or a niche asset class (for example, minor commodities, crypto-assets
or collectibles).

Low

The product provides exposure to a small number of holdings (for example, fewer than 25 securities) or a narrow asset class, sector or geographic market (forexample, a single major commodity (e.g. gold) or equities from a single emerging market economy).

MediumThe product provides exposure to a moderate number of holdings (for example, up to 50 securities) in at least one broad asset class, sector or geographic
market (for example, Australian fixed income securities or global natural resources).

High

The product provides exposure to a large number of holdings (for example, over 50 securities) in multiple broad asset classes, sectors or geographic markets(for example, global equities).

Very highThe product provides exposure to a large number of holdings across a broad range of asset classes, sectors and geographic markets with limited correlation
to each other.

Consumer’s intended investment timeframe
Minimum

The minimum suggested timeframe for holding the product. Typically, this is the rolling period over which the investment objective of the product is likely to beachieved.

Consumer’s Risk (ability to bear loss) and Return profile
This TMD uses the Standard Risk Measure (SRM) to estimate the likely number of negative annual returns for this product over a 20 year period, using the guidance and methodology
outlined in the Standard Risk Measure Guidance Paper For Trustees (note the bands in the SRM guidance differ from the bands used in this TMD). However, SRM is not a complete
assessment of risk and potential loss. For example, it does not detail important issues such as the potential size of a negative return (including under conditions of market stress) or thata positive return could still be less than a consumer requires to meet their investment objectives/needs. The SRM methodology may be supplemented by other risk factors. For example,
some products may use leverage, derivatives or short selling; may have liquidity or withdrawal limitations; may have underlying investments with valuation risks or risks of capital loss;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.
A consumer’s desired product return profile would generally take into account the impact of fees, costs and taxes.
For the relevant part of the consumer’s portfolio, the consumer:

Low• has a conservative or low risk appetite,• seeks to minimise volatility potential losses (e.g. has the ability to bear up to 1 negative return over a 20 year period (SRM 1 to 2)), and• is comfortable with a low target return profile.
The consumer typically prefers stable, defensive assets (such as cash).

9

TARGET MARKET DETERMINATION | Betashares Energy Transition Metals ETF ASX: XMETDefinitions
Term

Definition

Consumer’s Risk (ability to bear loss) and Return profile
For the relevant part of the consumer’s portfolio, the consumer:

Medium• has a moderate or medium risk appetite,• seeks low volatility and potential losses (e.g. has the ability to bear up to 4 negative returns over a 20 year period (SRM 3 to 5)), and• is comfortable with a moderate target return profile.
The consumer typically prefers defensive assets (for example, fixed income).
For the relevant part of the consumer’s portfolio, the consumer:High• has a high risk appetite,• can accept high volatility and potential losses (e.g. has the ability to bear up to 6 negative returns over a 20 year period (SRM 5 or 6)), and• seeks high returns (typically over a medium or long timeframe).
The consumer typically prefers growth assets (for example, shares and property).
For the relevant part of the consumer’s portfolio, the consumer:

Very high• has a very high risk appetite,• can accept very high volatility and potential losses (e.g. has the ability to bear 6 to 7 negative returns over a 20 year period (SRM 6 or 7),• seeks to maximise returns (typically over a medium or long timeframe).
The consumer typically prefers high growth assets (such as high conviction portfolios, hedge funds and alternative investments).
For the relevant part of the consumer’s portfolio, the consumer:

Extremely high• has an extremely high risk appetite,• can accept significant volatility and losses, and• seeks to obtain accelerated returns (potentially in a short timeframe).
The consumer seeks extremely high risk, speculative or complex products which may have features such as significant use of derivatives, leverageor short positions or may be in emerging or niche asset classes (for example, crypto-assets or collectibles).

10 TARGET MARKET DETERMINATION | Betashares Energy Transition Metals ETF ASX: XMETDefinitions
Term

Definition

Consumer’s need to access capitalThis consumer attribute addresses the likely period of time between the making of a request for redemption/withdrawal (or access to investment proceeds more generally) and thereceipt of proceeds from this request under ordinary circumstances. Issuers should consider both the frequency for accepting the request and the length of time to accept, process
and distribute the proceeds of such a request. To the extent that the liquidity of the underlying investments or possible liquidity constraints (e.g. ability to stagger or delay redemptions)
could impact this, this is to be taken into consideration in aligning the product to the consumer’s need to access capital. Where a product is held on investment platforms, distributors
also need to factor in the length of time platforms take to process requests for redemption for underlying investments. Where access to investment proceeds from the product is likely
to occur through a secondary market, the liquidity of the market for the product should be considered.
Distributor reporting
Section 994F(6) of the Act requires distributors to notify the issuer if they become aware of a significant dealing in the product that is notconsistent with the TMD. Neither the Act nor ASIC defines when a dealing is ‘significant’ and distributors have discretion to apply its ordinary
meaning.
The issuer will rely on notifications of significant dealings to monitor and review the product, this TMD, and its distribution strategy, and to meet its
own obligation to report significant dealings to ASIC.
Dealings outside this TMD may be significant because:• they represent a material proportion of the overall distribution conduct carried out by the distributor in relation to the product, or• they constitute an individual transaction which has resulted in, or will or is likely to result in, significant detriment to the consumer (or class of
consumer).
Significant dealings

In each case, the distributor should have regard to:• the nature and risk profile of the product (which may be indicated by the product’s risk rating or withdrawal timeframes),• the actual or potential harm to a consumer (which may be indicated by the value of the consumer’s investment, their intended product use or
their ability to bear loss), and• the nature and extent of the inconsistency of distribution with the TMD (which may be indicated by the number of red ratings attributed to theconsumer).
Objectively, a distributor may consider a dealing (or group of dealings) outside the TMD to be significant if:
•
•
•
•

11

it constitutes more than half of the distributor’s total retail product distribution conduct in relation to the product over the reporting quarter,
the consumer’s intended product use is solution / standalone,
the consumer’s intended product use is core component or higher and the consumer’s risk and return profile is low, or
the relevant product has a green rating for consumers seeking extremely high risk/return.

TARGET MARKET DETERMINATION | Betashares Energy Transition Metals ETF ASX: XMETImportant notice
The information contained in this document is general information only and does not constitute personal financial advice. It does not take into account any person’s financial objectives, situation or needs.
The information is not a recommendation to make any investment or adopt any investment strategy. Investments in any Betashares Fund are subject to investment risk and investors may not get back the fullamount originally invested. Any person wishing to invest in a Betashares Fund should obtain a copy of the relevant PDS from www.betashares.com.au and obtain financial advice in light of their individual
circumstances. To the extent permitted by law Betashares accepts no liability for any loss from reliance on this information.
Any Betashares Fund that seeks to track the performance of a particular financial index is not sponsored, endorsed, issued, sold or promoted by the provider of the index. No index provider makes any
representation regarding the advisability of buying, selling or holding units in the Betashares Funds.