{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The UBS (Lux) Fund Solutions - Factor MSCI EMU Low Volatility UCITS ETF is a UCITS-compliant ETF that primarily uses physical replication (full replication) of the MSCI EMU Select Dynamic 50% Risk Weighted Index. The KIID and PRIIPs KID documents indicate that derivatives may be used only occasionally for efficiency or where direct replication is not practicable, but this use is limited and primarily for risk management or tracking efficiency, not as an inherent part of the investment strategy. There is no mention of synthetic replication, swap agreements, or funded/unfunded swaps. The fund does not employ leverage, inverse exposure, or capital protection mechanisms. The underlying assets are equities from the EMU region, which are liquid and transparent. The risk profile is medium (4 out of 7 in PRIIPs KID, 6 in KIID but explained by equity volatility rather than complexity). Costs are straightforward with a TER of 0.25% and no performance fees or complex fee structures. The PRIIPs KID explicitly states the product is 'not simple and may be difficult to understand,' but this is likely due to the index complexity and equity market volatility rather than structural complexity such as derivatives or leverage. The monthly factsheet confirms physical replication and no use of swaps or synthetic structures. Therefore, under MiFID II criteria, this ETF is classified as non-complex."
}