{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Vanguard ESG Developed Asia Pacific All Cap UCITS ETF (USD) Distributing",
    "investment_objective": "Passive management/indexing approach to track the FTSE Developed Asia Pacific All Cap Choice Index with ESG screening",
    "primary_asset_class": "Equity",
    "geographic_focus": "Developed markets of Asia Pacific region including Japan",
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication or representative sampling of the underlying index securities, with no mention of synthetic replication or swap agreements. The Fund may use derivatives only for risk reduction or cost management, not as an inherent part of the investment strategy, so derivatives are marked false. There is no leverage or inverse exposure. The underlying assets are equities in developed Asia Pacific markets, screened for ESG criteria, with no complex structured products or contingent bonds. The risk profile is medium (4-6 range in KIID and 4 in PRIIPs KID), consistent with equity market risk but no complexity flags such as capital protection or structured features. Costs are straightforward with a single ongoing charge figure and no performance fees or swap fees. Counterparty risk is disclosed but limited to safekeeping and incidental derivative use, not significant exposure. The PRIIPs KID states the fund is 'not simple and may be difficult to understand' due to ESG screening and index construction, but this does not trigger complexity under MiFID II as no synthetic or leveraged elements exist. The factsheet confirms physical replication, no synthetic or swap usage, and no leverage. Overall, the ETF is a standard physical replication equity UCITS ETF with ESG screening, no leverage, no synthetic replication, and no complex underlying assets, thus classified as non-complex under MiFID II."
}