{
    "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 Silver ETC is a physically backed exchange traded certificate (ETC) that aims to track the spot price of silver by holding physical silver bullion. The replication method is explicitly physical, with silver bullion held in allocated accounts at JPMorgan Chase Bank's London vaults. There is no mention of synthetic replication, swap agreements, or derivative instruments used to achieve the investment objective. The product does not employ leverage, inverse exposure, or capital protection mechanisms. The risk indicator is high (6 out of 7), reflecting the inherent volatility and market risk of silver as a commodity, but this does not stem from structural complexity or derivative usage. Costs are straightforward with a fixed management fee of 0.19% p.a. 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 does not imply complexity under MiFID II. There are no complex underlying assets such as contingent convertible bonds or CLOs. The product\u2019s risk arises from commodity price volatility and issuer/counterparty credit risk, but no significant counterparty risk from derivatives is disclosed. The PRIIPs KID and factsheet confirm no use of derivatives or swaps, and no leverage or inverse exposure. Therefore, under MiFID II criteria, this ETC is classified as non-complex."
}