{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The iShares Asia Pacific Dividend UCITS ETF aims to replicate the Dow Jones Asia/Pacific Select Dividend 50 Index by physically holding the underlying equity securities in similar proportions. The KIID and PRIIPs KID documents confirm the fund uses physical replication and direct investment in listed equities, with no mention of synthetic replication, swap agreements, or derivative instruments as a core part of the investment strategy. While the fund may use financial derivative instruments (FDIs) for investment purposes, this is limited and not inherent to the strategy, thus derivatives are considered non-complex in this context. There is no leverage, inverse exposure, or capital protection features. The risk profile is medium (4 out of 7 in PRIIPs KID, 6 in KIID but driven by equity market risk and sector concentration rather than complexity). The fund engages in short-term securities lending to offset costs, but this does not increase complexity. The monthly factsheet confirms physical replication, no use of swaps or synthetic structures, and a straightforward portfolio of 48-50 equity holdings. No complex underlying assets such as contingent convertible bonds or CLOs are held. Costs are standard with no performance fees or swap fees. No complexity warnings or comprehension warnings appear in the PRIIPs KID. Therefore, under MiFID II criteria, this ETF is classified as non-complex."
}