{
    "type": "ETF",
    "ucits": true,
    "fund_name": "VanEck Genomics and Healthcare Innovators UCITS ETF",
    "investment_objective": "Replicate the MVIS Global Future Healthcare ESG Index",
    "primary_asset_class": "Equity",
    "geographic_focus": "Global, with major holdings in the United States and other developed markets",
    "replication_method": "physical",
    "swaps": true,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": "Use of equity swaps and other derivatives for index replication; sector concentration in genomics and healthcare technology",
    "classification": "complex",
    "supporting_data": "The Fund primarily uses physical replication investing directly in underlying equity securities of the MVIS Global Future Healthcare ESG Index. However, the KIID and PRIIPs KID explicitly state that the Fund may also use financial derivative instruments (FDIs) including equity swaps and swaps on the Index, currency forwards, and non-deliverable forwards (NDFs). The presence of swaps, even if used for replication or tracking efficiency, triggers complexity under MiFID II. The derivatives are not used for leverage or amplification but as part of the replication strategy. The Fund is UCITS compliant and does not employ leverage or inverse strategies. The risk profile is high (7/7 in KIID, 5/7 in PRIIPs), reflecting sector concentration and equity market risk rather than leverage. The Fund invests in a specialized, thematic equity index focused on genomics and healthcare innovation, which may be less familiar and harder to understand for retail investors. The monthly factsheet confirms physical full replication as the primary method but does not exclude derivative use. The presence of swaps and derivative instruments, combined with a high risk rating and sector concentration, leads to a classification of complex under MiFID II. There are no capital protection or structured features. Costs are straightforward with no performance fees, but swap usage implies additional complexity. No leverage or inverse exposure is present. The PRIIPs KID does not carry a specific comprehension warning but highlights medium-high risk and concentration risk. Overall, the complexity arises mainly from the use of swaps and derivatives in replication and the specialized thematic nature of the underlying index.",
    "risk_level_assessment": "The Fund\u2019s stated risk profile is high (7/7 in KIID, 5/7 in PRIIPs), consistent with equity market risk and sector concentration rather than leverage or structured features. This aligns with the complexity classification driven by derivative use and thematic concentration."
}