{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Xtrackers Nikkei 225 UCITS ETF is a UCITS-compliant ETF that aims to replicate the performance of the Nikkei Stock Average Index by buying all or a substantial number of the underlying securities. The KIID and PRIIPs KID documents explicitly state that the fund attempts to replicate the index physically, with no mention of synthetic replication or use of swap agreements. While the fund may use derivatives to manage risk or improve efficiency, this is described as ancillary and not an inherent part of the investment strategy, so derivatives are not considered a complexity factor here. There is no leverage, inverse exposure, or capital protection mechanism. The risk profile is medium-high (5 out of 7), reflecting market volatility and equity risk rather than structural complexity. The fund uses securities lending to generate additional income, but this does not increase complexity under MiFID II. No references to contingent bonds, complex structured products, or significant counterparty risk are found. The index tracked is a well-known, rules-based equity index composed of liquid Japanese stocks, with no complex features such as barrier options or contingent return formulas. Costs are straightforward, with a low ongoing charge and no performance fees or swap fees. Overall, the fund exhibits a straightforward physical replication strategy with direct investment in liquid equities, minimal derivative use for risk management, no leverage, and no complex underlying assets, leading to a non-complex classification under MiFID II."
}