{
    "type": "ETF",
    "ucits": true,
    "fund_name": "iShares Moderate Portfolio UCITS ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The iShares Moderate Portfolio UCITS ETF is an actively managed multi-asset UCITS ETF domiciled in Ireland, investing predominantly in other UCITS funds and ETFs that track indices meeting ESG criteria. The KIID and PRIIPs KID documents confirm that the Fund uses physical investments via underlying funds rather than synthetic replication. There is no mention of synthetic replication, swap agreements, total return swaps, or derivative instruments used as part of the investment strategy, only limited use of derivatives for risk reduction and cost management, which does not trigger complexity under MiFID II. The Fund does not employ leverage, inverse or amplified exposure, nor does it invest in complex underlying assets such as contingent convertible bonds or structured products. The risk profile is moderate (risk level 3-4 out of 7), consistent with a non-complex multi-asset fund. Costs are straightforward with no performance fees or swap fees. The monthly factsheet confirms the Fund holds a diversified portfolio of UCITS ETFs and mutual funds with no direct derivative or swap exposure. Counterparty risk is disclosed as a standard risk related to safekeeping and securities lending but is not significant enough to classify the Fund as complex. There are no capital protection or structured features. Overall, the Fund\u2019s structure, investment approach, and risk profile align with a non-complex classification under MiFID II."
}