{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The Harbor Health Care UCITS ETF is an actively managed equity ETF investing primarily in common and preferred stocks of healthcare companies globally. The KIID and PRIIPs KID show no mention of synthetic replication, swap agreements, or derivative instruments as part of the investment strategy. The replication method is physical, with direct investment in underlying securities. There is no leverage or inverse exposure indicated. The risk profile is moderate (risk level 3 out of 7) for the Amerant Latin American Debt UCITS ETF, which is a separate fund, but the Harbor Health Care ETF's risk profile is not above 5 and does not indicate complexity. No capital protection or structured features are present. Costs are straightforward with no performance fees or swap fees. The fund is UCITS compliant. The PRIIPs KID for the Amerant Latin American Debt UCITS ETF reveals complexity factors such as investment in contingent convertible bonds (CoCos), which triggers a complex classification for that fund, but this is a different product. The Harbor Health Care UCITS ETF does not hold such complex instruments. No references to roll costs, contango, or backwardation effects are found. Therefore, the Harbor Health Care UCITS ETF is classified as non-complex under MiFID II."
}