{
    "type": "ETF",
    "ucits": true,
    "fund_name": "HSBC NASDAQ Global Climate Tech UCITS ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Use of total return swaps up to 10% of assets",
        "Counterparty risk disclosed",
        "Investment in emerging markets",
        "Use of derivatives for investment and efficient portfolio management",
        "Securities lending up to 30% of assets"
    ],
    "classification": "complex",
    "supporting_data": "The Fund aims to track the NASDAQ CTA Global Climate Technology Index primarily through physical replication of shares in the index. However, the Fund may invest up to 10% of its assets in total return swaps and contracts for difference, with expected usage not exceeding 5%. The Fund also uses derivatives for efficient portfolio management and investment purposes. The KIID and PRIIPs KID disclose counterparty risk and derivatives risk explicitly, indicating the presence of derivative instruments beyond mere risk management. Securities lending up to 30% of assets adds further complexity. The Fund invests in emerging markets and thematic climate technology companies, which may add to underlying asset complexity. The risk profile is high (category 5-6), reflecting volatility and derivative exposure. Although the Fund uses physical replication primarily, the presence of swap usage, counterparty risk, and derivative instruments for investment purposes triggers MiFID II complexity classification. There is no leverage or inverse exposure, and no capital protection features. The Fund is UCITS compliant and an ETF. The complexity arises mainly from the partial use of total return swaps and derivatives, counterparty risk, and the thematic, emerging market underlying assets. The PRIIPs KID does not carry a specific comprehension warning but confirms derivative and counterparty risks. The monthly factsheet confirms physical replication as the main method but acknowledges swap usage up to 10%. Therefore, under MiFID II, the Fund is classified as complex due to swap usage and derivative exposure inherent in the investment strategy, despite the physical replication approach and moderate risk profile."
}