{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Avantis Emerging Markets Equity UCITS ETF is classified as non-complex under MiFID II based on the following analysis:1. **Replication Method**: The fund uses physical replication (direct investment in equities and equity-related securities) rather than synthetic replication. There are no references to swaps, derivatives, or counterparty risk in the KIID or PRIIPs documents.2. **Leverage and Inverse Exposure**: The fund does not employ leverage or inverse strategies. The investment objective is long-term capital appreciation through direct equity investments, with no mention of amplified returns or gearing.3. **Underlying Asset Complexity**: The fund invests in liquid, transparent equities and equity-related securities in emerging markets. There are no references to complex structured products, contingent convertible bonds, or illiquid securities. The fund explicitly states it does not invest in contingent convertible bonds.4. **Capital Protection and Structured Features**: The fund does not offer capital guarantees, principal protection, or structured return features. The risk profile is straightforward, with a risk rating of 6 (out of 7) based on emerging market exposure.5. **Risk Profile and Disclosures**: The risk disclosures are clear and relate primarily to market, political, and liquidity risks typical of emerging market equities. There are no warnings about suitability for retail investors or extensive counterparty risk explanations.6. **Costs and Charges**: The fee structure is simple, with an ongoing charge of 0.35% and no performance fees or complex fee arrangements.7. **PRIIPs KID and Factsheet**: The PRIIPs KID does not include a comprehension warning, and the factsheet (if available) would likely confirm the physical replication method and lack of derivative usage.**Counterargument and Override**: While the fund invests in emerging markets, which may introduce complexity due to less stringent regulatory standards, the fund's direct equity investment strategy and lack of derivative usage align with MiFID II's non-complex criteria. The complexity of the underlying markets does not inherently make the fund complex under MiFID II, as the fund's structure remains transparent and easily understandable for retail investors.",
    "confidence": 95
}