{
    "type": "ETF",
    "ucits": true,
    "fund_name": "VanEck Morningstar US ESG Wide Moat UCITS ETF",
    "investment_objective": "Track the price and yield performance of the Morningstar US Sustainability Moat Focus Index",
    "primary_asset_class": "Equity",
    "geographic_focus": "United States",
    "replication_method": "physical",
    "swaps": true,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": "Swaps usage for index replication, ESG screening, optimized sampling",
    "classification": "complex",
    "supporting_data": "The Fund primarily invests in US equity securities aiming to replicate the Morningstar US Sustainability Moat Focus Index using a physical replication strategy with direct investment in underlying equities. However, the KIID and PRIIPs KID explicitly state that the Fund may also use financial derivative instruments (FDIs) such as futures, swaps, and non-deliverable forwards (NDFs) to achieve its investment objective, particularly when full physical replication is not practical or cost efficient. The mention of swaps and other derivatives, even if used for replication rather than risk management, triggers complexity under MiFID II. The Fund is UCITS compliant and does not employ leverage or inverse strategies. The risk profile is medium-high (5 out of 7), reflecting equity market risk and concentration risk, but not derivative amplification or leverage. The Fund does not have capital protection or structured features. The use of swaps and other FDIs, combined with the complexity of the underlying ESG-screened index and optimized sampling methodology, leads to a classification of 'complex' under MiFID II. The PRIIPs KID does not carry a specific comprehension warning but confirms derivative usage. The monthly factsheet confirms physical replication as primary but acknowledges swap usage, supporting the complexity classification. Costs are straightforward with no performance fees, but swap and derivative costs are implicit. Overall, the presence of swap agreements and derivative instruments as an inherent part of the replication strategy, even without leverage, mandates a 'complex' classification under MiFID II rules."
}