{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Xtrackers Portfolio UCITS ETF is a Luxembourg-domiciled UCITS-compliant ETF that invests primarily in a diversified portfolio of other ETFs linked to equities and fixed income. The fund is actively managed but does not use synthetic replication or swap-based structures; the factsheet explicitly states the portfolio methodology is 'Direct Replication (physically)'. There is no mention of leverage, inverse exposure, or capital protection mechanisms. The fund may use derivatives only for risk management purposes, not as an inherent part of the investment strategy, and there is no indication of funded or unfunded swaps or counterparty exposure beyond normal securities lending arrangements. The risk profile is moderate (risk category 5 in KIID, 3 in PRIIPs KID), consistent with a balanced equity and bond exposure, without complex derivative risk disclosures or warnings about suitability only for sophisticated investors. Costs are straightforward with a single ongoing charge of 0.70%, no performance fees, and no swap or derivative fees. The underlying assets are ETFs that themselves invest in liquid equities and bonds, with no indication of complex structured products or contingent convertible bonds. The PRIIPs KID does not include a comprehension warning, and the fund\u2019s strategy and structure are transparent and linear, tracking diversified indices via physical holdings. Therefore, under MiFID II criteria, this ETF is classified as non-complex."
}