{
    "type": "ETF",
    "ucits": true,
    "fund_name": "SPDR MSCI Europe Communication Services UCITS ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Fund is a UCITS-compliant ETF domiciled in Ireland, tracking the MSCI Europe Communication Services 35/20 Capped Index. The investment objective is to replicate the performance of European large and mid-sized companies in the Communication Services sector using a physical replication strategy, aiming to hold all securities in the index with approximate weightings. The KIID and PRIIPs KID documents confirm that derivatives may be used only for efficient portfolio management, not as an inherent part of the investment strategy, and there is no mention of synthetic replication, swap agreements, or counterparty risk exposure. The factsheet confirms physical replication and no use of synthetic instruments or leverage. The risk profile is medium (4 out of 7 in PRIIPs KID, 6 out of 7 in KIID, reflecting market volatility and concentration risk, not complexity). There are no capital protection features, no leverage, no inverse or leveraged exposure, and no complex underlying assets such as contingent convertible bonds or CLOs. Costs are straightforward with a TER of 0.18%, no performance fees, and no swap or derivative fees. The Fund uses securities lending up to 40% of NAV, which is common and not a complexity driver. No comprehension warnings or complexity flags appear in the PRIIPs KID. Therefore, under MiFID II criteria, this ETF is classified as non-complex."
}