{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Vanguard ESG North America All Cap UCITS (USD) Distributing",
    "investment_objective": "Passive management/indexing approach to track the FTSE North America All Cap Choice Index through physical acquisition of securities",
    "primary_asset_class": "Equity",
    "geographic_focus": "United States and Canada",
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication with a representative sampling technique to track the FTSE North America All Cap Choice Index. There is no mention of synthetic replication, swap agreements, or total return swaps. Derivatives may be used 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 large-, mid-, and small-cap equities in North America, which are liquid and transparent. The risk profile is medium-high (risk level 5-6) due to equity market exposure and index tracking risks, but this does not imply complexity under MiFID II. No capital protection or structured features are present. Costs are straightforward with a low ongoing charge of 0.12% and no performance fees or swap fees. The PRIIPs KID includes a comprehension warning stating the fund 'is not simple and may be difficult to understand,' but this relates to ESG screening and index complexity rather than structural complexity such as derivatives or leverage. The factsheet confirms physical replication and no use of swaps or synthetic structures. Overall, the fund is a UCITS ETF with physical replication, no leverage, no synthetic elements, and invests in liquid equities, leading to a non-complex classification under MiFID II."
}