{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Vanguard S&P 500 UCITS ETF (USD) Distributing",
    "investment_objective": "Passive management/indexing to track the Standard and Poor's 500 Index through physical acquisition of securities",
    "primary_asset_class": "Equity",
    "geographic_focus": "United States",
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Vanguard S&P 500 UCITS ETF uses physical replication by investing directly in the constituent securities of the S&P 500 Index, with sampling only when full replication is impracticable. There is no mention of synthetic replication, swap agreements, or total return swaps. The fund may use derivatives only for risk reduction or cost management, not as an inherent part of the investment strategy, so derivatives are marked false. There is no leverage, inverse or amplified exposure. The underlying assets are large-cap US equities, which are liquid and transparent. No capital protection or structured features are present. The risk rating is 5 out of 7, reflecting market risk but not complexity. Costs are straightforward with a low ongoing charge of 0.07%, no performance fees, and no swap or derivative fees. The PRIIPs KID explicitly states the fund is 'not simple and may be difficult to understand' but this is a standard caution for index funds and does not indicate complexity under MiFID II. The monthly factsheet confirms physical replication, no synthetic structures, and no leverage. Counterparty risk is minimal and related only to custody and limited derivative use for risk management. Overall, the fund exhibits none of the MiFID II complexity triggers such as synthetic replication, leverage, complex underlying assets, or capital protection mechanisms. Therefore, it is classified as non-complex."
}