{
    "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 Palladium ETC is a physically backed exchange traded certificate (ETC) that aims to track the spot price of palladium by holding physical palladium bullion in allocated accounts. The replication method is explicitly physical, with no mention of synthetic replication, swap agreements, or derivative instruments as part of the investment strategy. There is no leverage or inverse exposure indicated. The product does not invest in derivatives or complex structured products; it holds physical commodity assets. The risk indicator is high (6 out of 7), reflecting the inherent volatility and market risk of the underlying commodity, not complexity from financial engineering. 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 capital protection or structured features. Counterparty risk exists due to issuer and custodian default risk, but this is typical for ETCs and disclosed clearly. No complexity warnings or comprehension warnings are present in the PRIIPs KID. The product\u2019s risk profile aligns with commodity price risk rather than structural complexity. Therefore, under MiFID II criteria, this ETC is classified as non-complex."
}