{
    "type": "ETF",
    "ucits": true,
    "fund_name": "iShares MSCI EM Small Cap UCITS ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF is a UCITS-compliant exchange-traded fund that aims to track the MSCI Emerging Markets Small Cap Index through physical replication, primarily investing directly in equity securities of small-cap companies in emerging markets. The KIID and PRIIPs KID documents confirm the use of 'optimising techniques' which may include limited use of financial derivative instruments (FDIs) for direct investment purposes, but these are not inherent to the strategy and are used to enhance tracking rather than to create synthetic exposure. There is no mention of synthetic replication, swap agreements, total return swaps, or funded/unfunded swap structures. The monthly factsheet explicitly states the product structure as 'Physical' and does not indicate any use of leverage, inverse exposure, or complex underlying assets such as contingent convertible bonds or CLOs. The risk profile is medium (4 out of 7 in PRIIPs KID, 6 in KIID but consistent with equity risk in emerging markets), with no capital protection or structured features. Costs are straightforward with no performance fees or swap fees. Counterparty risk is disclosed as a general risk related to safekeeping and derivative counterparties but is not significant or indicative of synthetic replication. Securities lending is used but revenue sharing does not increase costs and is standard practice. No complexity flags such as capital guarantees, leverage, or complex derivatives are present. Therefore, under MiFID II criteria, this ETF is classified as non-complex."
}