{
    "type": "ETC",
    "ucits": false,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The SMO Physical Gold ETC is a secured debt security linked directly to physical gold, backed by physical London Bullion Market Association (LBMA) gold held with HSBC as custodian. The product uses physical replication with a metal entitlement per security, and there is no mention of synthetic replication, swap agreements, or derivative instruments as part of the investment strategy. There is no leverage, inverse exposure, or capital protection features. The risk profile is medium (risk level 4), consistent with direct exposure to gold price fluctuations, without derivative-related complexity or counterparty risk beyond issuer default risk. Costs are straightforward with no performance fees or swap fees. The product is not UCITS compliant, but this does not affect complexity classification. No complex underlying assets or structured features are present. The PRIIPs KID and factsheet do not indicate any additional complexity factors such as derivative usage or complex indices. Therefore, under MiFID II criteria, this ETC is classified as non-complex."
}