{
    "type": "ETF",
    "ucits": true,
    "fund_name": "VanEck Rare Earth and Strategic Metals UCITS ETF",
    "investment_objective": "Replicate the MVIS Global Rare Earth/Strategic Metals Index by investing primarily in underlying equity securities of companies involved in rare earth and strategic metals sectors.",
    "primary_asset_class": "Equity",
    "geographic_focus": "Global with significant exposure to emerging markets including China (Shanghai and Shenzhen Stock Exchanges), US, Australia, Canada, Chile, France, Netherlands",
    "replication_method": "physical",
    "swaps": true,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Use of equity swaps and index swaps",
        "Exposure to emerging markets",
        "Investment in smaller and natural resources companies",
        "Derivative instruments used for efficient portfolio management rather than inherent leverage",
        "No capital protection or structured features"
    ],
    "classification": "complex",
    "supporting_data": "The Fund primarily uses physical replication investing directly in underlying equities, ADRs, and GDRs of companies generating significant revenues from rare earth and strategic metals. However, the Fund may also invest in financial derivative instruments including equity swaps, index swaps, futures, options, currency forwards, and non-deliverable forwards. These derivatives are used for efficient portfolio management and to manage tracking error, not for leverage or amplification of returns. The presence of swaps (equity swaps and index swaps) triggers complexity classification under MiFID II. The Fund is UCITS compliant and does not employ leverage or inverse strategies. The risk profile is high (6 out of 7) reflecting market risk, emerging market exposure, and sector concentration in natural resources and smaller companies, which adds to complexity. There are no capital protection or structured product features. Costs are straightforward with no performance fees, but swap usage implies additional derivative-related risks and counterparty exposure. The PRIIPs KID does not carry a specific comprehension warning but highlights the need for investors to have sufficient knowledge and understanding of the product and market. The monthly factsheet confirms physical full replication and quarterly rebalancing, with no indication of synthetic replication beyond the permitted use of swaps for risk management. Overall, the use of swaps and derivative instruments, even if not leveraged, combined with sector and geographic risks, leads to a MiFID II classification as complex."
}