{
    "type": "ETC",
    "ucits": false,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The Invesco Physical Platinum ETC is a physically backed exchange traded certificate (ETC) that aims to track the spot price of platinum by holding physical platinum bullion. The replication method is explicitly physical, with no mention of synthetic replication, swap agreements, or derivative instruments as part of the investment strategy. The product does not use leverage or inverse exposure, nor does it invest in complex underlying assets such as contingent convertible bonds or CLOs. The risk indicator is medium-high (5/7), reflecting commodity price volatility and issuer/counterparty risk, but this does not stem from structural complexity or derivative usage. Costs are straightforward with a fixed management fee and no performance fees or swap fees. The product is not UCITS compliant, as it is an ETC (a debt instrument backed by physical commodity), but this alone does not imply complexity under MiFID II. There are no capital protection or structured features. The risk disclosures focus on market risk, issuer default risk, and currency risk, without complex derivative or counterparty risk disclosures. The monthly factsheet confirms physical collateralization with platinum held in allocated vaults and no use of derivatives or swaps. Therefore, under MiFID II criteria, this ETC is classified as non-complex because it uses physical replication, has no leverage, no synthetic or derivative exposure, and invests directly in a liquid, transparent underlying asset (physical platinum)."
}