{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Vanguard FTSE Developed Asia Pacific ex Japan UCITS ETF employs a passive, physical replication strategy by investing directly in the constituent securities of the FTSE Developed Asia Pacific ex Japan Index, using full replication or sampling only when full replication is impracticable. There is no indication of synthetic replication, swap agreements, or derivative instruments used as part of the investment strategy. Derivatives may be used only for risk reduction or cost management, not as an inherent element of the strategy, thus derivatives exposure is minimal and not complexity-driving. The fund does not use leverage, inverse or amplified exposure, nor does it invest in complex underlying assets such as contingent convertible bonds or CLOs. The risk profile is moderate (risk level 4 in PRIIPs KID, 6 in KIID due to equity exposure), consistent with a standard equity ETF. Costs are straightforward with a low ongoing charge (0.15%) and no performance fees or swap fees. Counterparty risk disclosures relate to standard operational risks, not to synthetic replication or unfunded swaps. The PRIIPs KID includes a standard comprehension warning that the product 'may be difficult to understand' but this is a generic statement for ETFs and does not reflect structural complexity. The factsheet confirms physical acquisition of securities, no use of swaps, and a transparent, liquid portfolio of large and mid-cap equities. No capital protection or structured features are present. Overall, the ETF aligns with MiFID II criteria for a non-complex financial instrument."
}