{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Lloyd Focused Equity UCITS ETF is a UCITS-compliant ETF that tracks the Solactive Lloyd Focused Equity Index using a passive, rules-based, physical replication methodology. The KIID and PRIIPs KID documents 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 (4 out of 7), consistent with direct equity exposure and market volatility, without additional complexity from derivatives or leverage. The Fund does not employ capital protection or structured features. Costs are straightforward, with no performance fees or swap fees, and the ongoing charges are typical for an ETF (0.85%). The PRIIPs KID includes a comprehension warning that the product 'is not simple and may be difficult to understand,' but this appears to be a standard caution for equity ETFs with focused strategies rather than an indication of structural complexity such as derivatives or leverage. No references to complex underlying assets like contingent convertible bonds or CLOs are present. The Fund invests in liquid, developed market equities screened for profitability and balance sheet strength, further supporting a non-complex classification. Therefore, under MiFID II criteria, this ETF is classified as non-complex."
}