{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Vanguard FTSE Developed Asia Pacific ex Japan UCITS ETF (USD) Accumulating",
    "investment_objective": "Passive management through physical acquisition of securities to track the FTSE Developed Asia Pacific ex Japan Index",
    "primary_asset_class": "Equity",
    "geographic_focus": "Developed markets in Asia and the Pacific Region, excluding Japan",
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication by investing directly in all or a representative sample of the underlying index 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 part of the strategy, so derivatives are marked false. There is no leverage, inverse or amplified exposure. The underlying assets are large and mid-cap equities in developed Asia Pacific markets, which are liquid and transparent. The risk rating is 6 in the KIID but 4 in the PRIIPs KID, reflecting market risk rather than structural complexity. No capital protection or structured features are present. Costs are straightforward with a low ongoing charge of 0.15% and no performance fees or swap fees. The PRIIPs KID includes a comprehension warning that the product 'is not simple and may be difficult to understand,' but this relates to the nature of equity index investing and currency risk rather than structural complexity or use of derivatives. The factsheet confirms physical replication, no use of swaps, and a straightforward index tracking approach. Overall, the ETF does not meet MiFID II criteria for a complex financial instrument."
}