{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The L&G Asia Pacific ex Japan ESG Exclusions Paris Aligned UCITS ETF is a UCITS-compliant ETF domiciled in Ireland that aims to track the Foxberry Sustainability Consensus Pacific ex Japan Total Return Index. The fund uses physical replication with an optimised/representative sampling approach to hold equity securities closely aligned to the index constituents. There is no indication of synthetic replication, swap agreements, or total return swaps. The fund does not employ leverage, inverse or amplified exposure, nor does it invest in complex underlying assets such as contingent convertible bonds or CLOs. Derivative instruments are only used potentially for efficient portfolio management or hedging, not as an inherent part of the investment strategy, and the documents do not describe derivative usage as a complexity factor. The risk rating is 6 on a 7-point scale, reflecting market risk typical of equity ETFs, but this is not driven by structural complexity. Costs are straightforward with a low ongoing charge (0.16%) and no performance fees or swap fees. The PRIIPs KID does not include any comprehension warnings or complexity flags. The fund\u2019s index is a sustainability-focused equity index with no complex structured features or capital protection mechanisms. Counterparty risk disclosures relate to normal operational risks, not to synthetic replication or unfunded swaps. Overall, the ETF exhibits characteristics of a standard physical equity ETF with ESG criteria and is therefore classified as non-complex under MiFID II."
}