{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "swaps": true,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": "Swap Counterparty Exposure",
    "classification": "complex",
    "supporting_data": "The Fund is a UCITS ETF physically replicating the STOXX China A 900 Minimum Variance Unconstrained AM Index, investing primarily in Chinese A-shares. The KIID and PRIIPs KID confirm that the Fund currently uses physical replication but retains the ability to switch to synthetic replication via a Swap Agreement with a Swap Counterparty. The presence of a Swap Agreement and explicit counterparty risk disclosures indicate the Fund has synthetic replication capacity and counterparty exposure, which under MiFID II rules classifies it as complex. There is no leverage, inverse or amplified exposure, and derivatives are only used as part of the swap structure, not for risk management alone. The risk profile is medium to high (risk level 6 in KIID, 4 in PRIIPs), reflecting emerging market and concentration risks rather than leverage or derivative complexity. The Fund does not employ capital protection or structured features. Costs are straightforward with no performance fees, but swap counterparty risk and replication risk are clearly disclosed. The complexity arises mainly from the potential use of unfunded swap agreements and counterparty risk, despite current physical replication. This means retail investors may find the product difficult to fully understand due to the embedded counterparty risk and the possibility of synthetic replication. The index tracked is a minimum variance index with volatility reduction aims, but this does not add complexity per se. No leverage or contingent bonds are involved. Therefore, the Fund is classified as complex under MiFID II due to the swap counterparty exposure and synthetic replication option."
}