{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Xtrackers MSCI Europe Value UCITS ETF",
    "investment_objective": "To reflect the performance of the MSCI Europe Enhanced Value TRN index by buying all or a substantial number of the securities in the index.",
    "primary_asset_class": "Equity",
    "geographic_focus": "Europe",
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The ETF physically replicates the MSCI Europe Enhanced Value TRN index by direct purchase of underlying securities, as confirmed by the factsheet stating 'Direct Replication (physically)'. There is no mention of synthetic replication, swap agreements, total return swaps, or derivative instruments used as part of the investment strategy, only derivatives used for risk management which does not trigger complexity. The fund does not employ leverage or inverse exposure. The risk profile is relatively high (6/7 in KIID, 5/7 in PRIIPs) due to equity market volatility and value strategy risks, but this does not imply complexity under MiFID II. The fund is UCITS compliant, with a straightforward index-tracking objective investing in liquid, transparent European equities. Costs are simple with a low ongoing charge (0.15%) and no performance fees or swap fees. Securities lending is minimal and disclosed transparently. No capital protection or structured features are present. The index tracked is a rules-based enhanced value index, which may cause tracking error but is not inherently complex. No contingent convertible bonds, CLOs, or other complex underlying assets are held. The PRIIPs KID does not include any comprehension warnings or complexity flags. Therefore, the ETF is classified as non-complex under MiFID II."
}