{
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": "Derivatives, Swaps, Emerging Markets, Index Concentration, Securities Lending, Counterparty Risk",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is physically replicated, tracking a transparent equity index (MSCI AC Far East ex Japan). It is UCITS-compliant and does not use significant leverage. However, it may use derivatives (including up to 10% in total return swaps and contracts for difference, though typically less than 5%) for efficient portfolio management and to gain exposure where direct investment is not possible. Securities lending is permitted up to 30% of assets (typically less than 25%). The ETF is listed and offers daily liquidity. The underlying index is concentrated, and the fund invests in emerging markets, introducing additional risks (market, liquidity, currency). Counterparty risk is present due to derivatives and securities lending, but these features are ancillary and within UCITS limits. The structure, risks, and objectives are clearly disclosed in the KIID. Despite derivative use, the primary replication method is physical, the risks are well-communicated, and the product is designed for retail investors with basic knowledge. Under MiFID II, all UCITS are automatically non-complex unless they are 'structured UCITS'u2014which this is not, as the derivative use is limited and for risk/cost management, not as a core strategy[1]. ESMA guidance confirms that UCITS ETFs using derivatives for efficient portfolio management, without making the product's risk profile difficult to understand, remain non-complex[2]. Therefore, this ETF is classified as non-complex, but investors should be aware of the risks associated with derivatives, securities lending, and emerging markets."
}