{
    "complex": false,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The L&G Pharma Breakthrough UCITS ETF is classified as non-complex under MiFID II based on the following analysis: 1. Physical replication method: The fund uses physical replication by investing directly in the securities represented in the Solactive Pharma Breakthrough Value Index. 2. No leverage or inverse exposure: There are no references to leverage, inverse strategies, or amplified returns. 3. No synthetic replication: The fund does not use swap agreements, total return swaps, or other derivative instruments for replication. 4. Straightforward investment objective: The fund aims to track the performance of an index of biotechnology companies focused on orphan drugs, with no complex structured features. 5. UCITS compliance: The fund is UCITS-compliant, which inherently limits the use of complex strategies. 6. Risk profile: While the fund is rated 6/7 on the risk scale, this is due to the nature of the underlying investments (small-cap biotech companies) rather than the fund's structure. 7. No capital protection or structured features: There are no capital guarantees, barrier options, or contingent return formulas. 8. Minimal derivative exposure: The only reference to derivatives is in the context of potential counterparty risk from third-party service providers, not as part of the fund's investment strategy. The fact sheet confirms the replication method is physical and backed by equities. The PRIIPs KID does not contain any comprehension warnings or indications of complexity. The fund's use of derivatives, if any, is likely limited to efficient portfolio management and does not materially alter the risk profile.",
    "confidence": 95
}