{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "physical",
        "leverage": false,
        "swaps": false,
        "derivatives": false,
        "inverse": false,
        "complex_factors": [
            "Minimum Volatility Index Strategy"
        ],
        "classification": "non-complex",
        "supporting_data": "The ETF tracks the MSCI Emerging Markets Minimum Volatility Index. While the index methodology involves selecting securities based on low volatility, which is a factor-based strategy, the ETF itself is a UCITS ETF and is passively managed, investing in underlying equity securities. The KID states that the fund uses 'optimising techniques' which 'may include the use of financial derivative instruments (FDIs)', but this is presented as a possibility for EPM and not as integral to replication. Given the primary investment in physical securities and the general presumption for UCITS ETFs, combined with the lack of explicit complexity drivers like swaps integral to replication or embedded derivatives, it is classified as non-complex. The 'Minimum Volatility' aspect refers to the strategy of the index and not an inherent structural complexity of the ETF itself in terms of derivatives or leverage. According to CESR/09-295, UCITS are automatically non-complex. The use of 'optimising techniques' is not sufficiently detailed to indicate complex derivative usage that would overturn the UCITS presumption. The risk profile is related to market volatility in emerging markets, not structural complexity."
    }
}