{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Unfunded total return swaps",
        "Derivative instruments usage",
        "Counterparty risk exposure",
        "Securities lending",
        "Concentration in thematic equity sector"
    ],
    "classification": "complex",
    "supporting_data": "The ETF is a UCITS-compliant equity ETF tracking the Indxx Global Internet of Things Thematic v2 Index. It primarily invests in equity securities and depositary receipts but uses synthetic replication via total return unfunded OTC swaps and exchange-traded equity futures to achieve its investment objective when physical replication is not practicable. The use of unfunded total return swaps introduces counterparty risk and derivative complexity. The fund also engages in securities lending and repurchase transactions for efficient portfolio management, adding operational and collateral risks. The risk profile is high (category 6 out of 7), reflecting volatility and derivative exposure. There is no leverage or inverse exposure, but the synthetic replication and swap usage are key complexity drivers under MiFID II. The PRIIPs KID confirms the use of unfunded OTC swaps and derivative instruments for investment purposes, not merely for hedging, reinforcing the classification as complex. The fund does not have capital protection or structured features but the derivative and counterparty risk elements, combined with the synthetic replication method, make it complex. The thematic concentration adds to risk but is not a complexity driver per se. No leverage or inverse terms are present. The monthly factsheet was not provided with additional contradictory information, so assumptions on swap usage stand. Overall, the ETF\u2019s synthetic replication via unfunded swaps and derivative use for investment purposes classify it as complex under MiFID II."
}