{
    "type": "ETF",
    "ucits": true,
    "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 employs a passive management approach through physical acquisition of securities, aiming to track the S&P 500 Index by investing in all or a representative sample of the index constituents. There is no indication of synthetic replication or use of swap agreements. 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 exposure, or capital protection features. The risk profile is medium-high (5 out of 7), reflecting equity market risk rather than complexity. The fund is UCITS compliant, domiciled in Ireland, and uses physical replication. The ongoing charges are low (0.07%), with no performance fees or complex fee structures. Counterparty risk disclosures relate to standard operational risks, not to synthetic structures. The PRIIPs KID includes a comprehension warning that the product 'may be difficult to understand,' but this is standard language for equity ETFs and does not reflect structural complexity. The factsheet confirms physical replication, no use of swaps, and direct investment in liquid, transparent US large-cap equities. No complex underlying assets such as contingent convertible bonds or CLOs are held. Therefore, under MiFID II criteria, this ETF is classified as non-complex."
}