{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Vanguard Germany All Cap UCITS ETF (EUR) Distributing",
    "investment_objective": "Passive management/indexing approach to track FTSE Germany All Cap Index through physical acquisition of securities",
    "primary_asset_class": "Equity",
    "geographic_focus": "Germany",
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF physically acquires securities to track the FTSE Germany All Cap Index, investing in substantially all constituent securities in proportion to the index. There is no mention 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, so derivatives are marked false. There is no leverage, inverse or amplified exposure. The risk rating is 5 out of 7, indicating medium-high risk typical for equity ETFs but not necessarily complexity. The fund is UCITS compliant. The PRIIPs KID explicitly states the fund is 'not simple and may be difficult to understand' but this relates to general market risks and currency risk, not structural complexity. The factsheet confirms physical replication, no use of swaps, and no leverage. The underlying assets are large, mid, and small cap German equities, which are liquid and transparent. No capital protection or structured features are present. Costs are straightforward with a low ongoing charge of 0.10% and no performance fees or swap fees. Overall, the fund exhibits none of the MiFID II complexity triggers such as synthetic replication, leverage, complex underlying assets, or capital protection mechanisms. Therefore, it is classified as non-complex."
}