{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivatives for investment purposes, synthetic exposure up to 10% (not expected to exceed 5%), securities lending up to 30% (not expected to exceed 25%), high concentration risk, emerging markets risk, counterparty risk",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is primarily physically replicated, tracking a transparent equity index (S&P India Tech Index). While it may use derivatives for efficient portfolio management and investment purposes (including up to 10% in total return swaps and contracts for difference, though not expected to exceed 5%), this use is not central to the ETF's strategy and is within typical UCITS limits. Securities lending is permitted but not expected to dominate the risk profile. The ETF does not employ leverage beyond temporary UCITS borrowing limits. The structure, risks, and investment objective are straightforward and disclosed in the KID. The ETF is authorized in Ireland and regulated by the Central Bank of Ireland, meeting UCITS standards for diversification, liquidity, and transparency. Under MiFID II, all UCITS are automatically non-complex unless they are structured UCITS (e.g., those with algorithm-based payoffs or similar complex features), which this ETF is not[1]. The use of derivatives for limited purposes and securities lending within UCITS rules does not, by itself, trigger a complex classification for a UCITS ETF, provided these features do not make the product difficult for a retail investor with basic knowledge to understand[1]. The ETF's risks (emerging markets, concentration, counterparty) are related to market and operational factors, not structural complexity. Therefore, despite some derivative use and securities lending, the ETF remains non-complex under MiFID II[1]."
}