{
    "type": "ETC",
    "ucits": false,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The product is an ETC (Exchange Traded Commodity) providing exposure to physical gold, backed by actual allocated physical gold held in custody. The replication method is physical, with no use of synthetic replication or swap agreements mentioned. There is no leverage, inverse or amplified exposure. The product hedges currency risk (GBP/USD) but this is a risk management derivative use, not an inherent strategy derivative use, so derivatives are marked false. The risk indicator is medium (4/7), consistent with commodity price volatility but not indicating complexity. There are no capital protection or structured features. Costs are straightforward with no performance fees or swap fees. The product is not UCITS compliant, as it is a debt security (ETC) rather than a collective investment scheme. The KIID and factsheet confirm no use of swaps or complex derivatives, and the underlying asset is physical gold, a liquid and transparent commodity. Although the product carries a retail investor caution in Spain about being 'not simple and may be difficult to understand,' this is likely due to the ETC legal structure and commodity exposure rather than complexity under MiFID II. No complex bonds, leverage, or structured features are present. Therefore, the product is classified as non-complex under MiFID II."
}