{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Lloyd Growth Equity UCITS ETF is a UCITS-compliant ETF that tracks the Solactive Lloyd Growth Equity Index using a passive, physical replication methodology. The KIID and PRIIPs KID explicitly state that the Fund invests directly in the underlying equity securities in proportion to the index weightings, with no mention of synthetic replication, swap agreements, or derivative instruments as part of the investment strategy. There is no leverage or inverse exposure indicated. The risk profile is medium-high (5 out of 7), reflecting market and currency risks typical of equity ETFs, but no complexity flags such as capital protection, structured features, or contingent bonds are present. Costs are straightforward with a single ongoing charge of 0.85%, no performance fees, and no swap or derivative fees. The PRIIPs KID includes a comprehension warning that the product 'is not simple and may be difficult to understand,' which is a standard regulatory caution for equity ETFs but does not reflect inherent complexity from derivatives or leverage. The Fund invests in liquid, publicly listed equities with a transparent, rules-based index methodology. No evidence of complex underlying assets, derivative counterparty risk, or capital protection mechanisms was found. Therefore, under MiFID II criteria, this ETF is classified as non-complex."
}