{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "physical",
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "leverage": false,
        "complex_factors": [],
        "classification": "non-complex",
        "supporting_data": "The ETF aims to replicate the FTSE EPRA/Nareit Developed Dividend + Index, which focuses on developed market REITs paying above-average dividends. The ETF primarily uses physical replication by investing in equity securities of these companies. While the KIID mentions 'optimising techniques' which 'may include the use of financial derivative instruments (FDIs)', it specifies these are for 'efficient portfolio management purposes (i.e. to reduce risk within the Fundu2019s portfolio, reduce investment costs and generate additional income)'. It also notes FDIs 'may be used for direct investment purposes', but the primary strategy is physical investment in index constituents. Crucially, the KIID states the ETF uses FDIs for currency hedging, which is a common and generally accepted use for efficient portfolio management that does not automatically render an ETF complex. There is no indication of synthetic replication or other complex derivative strategies integral to the investment objective. The fund also engages in short-term secured lending for additional income, which is a standard practice. The assessment of complexity under MiFID II for UCITS ETFs generally hinges on whether derivatives are integral to the strategy or used for hedging/efficiency, and whether the structure is easily understandable. Given the primary reliance on physical replication of a well-defined property index, and the limited stated use of derivatives for hedging and EPM, this ETF is presumed non-complex. The potential for derivatives for 'direct investment purposes' is noted but not elaborated as a core strategy element. Without specific details suggesting these derivatives are used in a way that creates counterparty, collateral, or other complex risks beyond normal EPM, the default UCITS presumption of non-complexity holds."
    }
}