{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Vanguard FTSE Developed Europe ex UK UCITS ETF employs a passive management approach through physical acquisition of securities, aiming to track the FTSE Developed Europe ex UK Index. The fund invests directly in the underlying equities, using full replication or representative sampling where full replication is impracticable. There is no indication of synthetic replication or use of swap agreements or total return swaps. The fund may use derivatives only for risk reduction or cost management, not as an inherent part of the investment strategy, so derivatives are considered non-complex in this context. There is no leverage, inverse or amplified exposure. The underlying assets are large and mid-cap equities in developed European markets, which are liquid and transparent. The risk rating is 6 on a 7-point scale in the KIID, reflecting equity market risk rather than structural complexity. The PRIIPs KID includes a comprehension warning stating the fund 'is not simple and may be difficult to understand,' but this is a standard phrase for equity ETFs and does not reflect structural complexity such as synthetic replication or leverage. The factsheet confirms physical replication, no use of swaps, and no complex underlying assets like contingent bonds or CLOs. Costs are straightforward with a low ongoing charge of 0.10%, no performance fees, and no complex fee structures. Counterparty risk is disclosed but limited to custodial and derivative counterparties, consistent with standard UCITS ETFs. Overall, the fund's structure, replication method, and underlying assets do not meet MiFID II criteria for complexity."
}