{
    "type": "ETF",
    "ucits": true,
    "fund_name": "HSBC Asia Pacific ex Japan Sustainable Equity UCITS ETF",
    "investment_objective": "Track the FTSE Asia Pacific ex Japan ESG Low Carbon Select Index",
    "primary_asset_class": "Equity",
    "geographic_focus": "Asia Pacific ex Japan",
    "replication_method": "physical",
    "swaps": true,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Swaps",
        "Concentration Risk",
        "Securities Lending"
    ],
    "classification": "complex",
    "supporting_data": "The Fund aims to physically replicate the FTSE Asia Pacific ex Japan ESG Low Carbon Select Index, investing primarily in equities. However, it may invest up to 15% of its assets in total return swaps and contracts for difference, with swap exposure not expected to exceed 5%. The Fund also engages in securities lending up to 30% of assets (not expected to exceed 25%). The use of total return swaps and contracts for difference, even at limited levels, introduces counterparty risk and derivative exposure, which under MiFID II rules classifies the ETF as complex. There is no leverage or inverse exposure. The risk profile is high (category 6 in the KIID), reflecting market volatility and concentration risk in the benchmark. The PRIIPs KID shows a lower risk rating (4/7), but confirms derivative use and counterparty risk disclosures. The Fund is UCITS compliant and uses physical replication primarily, but the presence of funded swaps and derivative contracts for investment purposes triggers complexity classification. No capital protection or structured features are present. Costs are straightforward with no performance fees, but derivative-related costs and securities lending are disclosed. The complexity arises mainly from the use of swaps and derivative contracts, counterparty risk, and the concentration of the underlying index, which may reduce transparency and increase tracking error risk."
}