{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Vanguard FTSE Developed Europe ex UK (EUR) Accumulating UCITS ETF",
    "investment_objective": "Passive management/indexing to track the FTSE Developed Europe ex UK Index",
    "primary_asset_class": "Equity",
    "geographic_focus": "Developed markets in Europe excluding the UK",
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication or representative sampling of the FTSE Developed Europe ex UK Index, investing directly in constituent securities. 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 6 in the KIID but 4 in the PRIIPs KID, reflecting equity market risk rather than complexity. The fund is UCITS compliant, domiciled in Ireland, and uses a straightforward index-tracking approach with transparent holdings. Costs are simple with a low ongoing charge of 0.10%, no performance fees, and no complex fee structures. The factsheet confirms physical acquisition of securities, no use of swaps or synthetic replication, and no complex underlying assets. The PRIIPs KID includes a comprehension warning that the product 'is not simple and may be difficult to understand,' but this is a standard phrase for ETFs tracking broad equity indices and does not reflect structural complexity. No capital protection or structured features are present. Counterparty risk is limited to custodial and minimal derivative use for risk management. Overall, the ETF exhibits none of the MiFID II complexity triggers such as synthetic replication, leverage, complex underlying assets, or capital protection mechanisms."
}