{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Alerian Midstream Energy Dividend UCITS ETF is a UCITS-compliant, passively managed ETF that physically replicates the Alerian Midstream Energy Corporation Dividend Index by investing directly in the equity securities of companies in proportion to their index weightings. The KIID and PRIIPs KID explicitly state the use of physical replication 'as far as possible and practical' and do not mention any use of swaps, synthetic replication, or derivative instruments as part of the investment strategy. There is no leverage, inverse exposure, or capital protection features. The risk profile is moderate to high (risk level 6 out of 7) due to sectoral and currency risks inherent in energy infrastructure equities, but this does not imply complexity under MiFID II. Costs are straightforward with a single ongoing charge of 0.49%, no performance fees, and no complex fee structures. The PRIIPs KID does not include any comprehension warnings or indications of complexity. No references to contingent bonds, structured products, or complex derivatives are found. Securities lending is mentioned but is a common practice and does not increase complexity. Therefore, the ETF is classified as non-complex under MiFID II."
}