{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Xtrackers FTSE Developed Europe Real Estate UCITS ETF is a UCITS-compliant ETF that physically replicates the FTSE EPRA/NAREIT Developed Europe Net Total Return Index by direct purchase of underlying securities, primarily shares of listed European real estate companies and REITs. The KIID and PRIIPs KID documents confirm the fund is passively managed with a straightforward index-tracking objective and no use of synthetic replication or swap agreements. The fund may use derivatives only for risk management purposes, not as an inherent part of the investment strategy, which does not trigger complexity under MiFID II. There is no leverage, inverse exposure, or capital protection mechanism. The risk profile is medium-high (risk category 5 out of 7), reflecting the underlying real estate sector volatility and regional concentration risk, but this does not imply complexity per MiFID II. The factsheet confirms direct physical replication and no synthetic or swap-based replication. Costs are simple, with a single ongoing charge of 0.33% and no performance fees or swap fees. No complex underlying assets such as contingent convertible bonds or CLOs are held. No references to funded or unfunded swaps, counterparty risk, or complex structured products are found. Therefore, the ETF is classified as non-complex under MiFID II."
}