{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "None identified",
    "classification": "non-complex",
    "supporting_data": "The SPDR S&P Europe Defense Vision UCITS ETF is a UCITS-compliant ETF, which under MiFID II is automatically classified as non-complex unless it is a structured UCITS or fails the Article 57 criteria[1]. The fund's investment policy is to track the performance of a transparent equity index using physical replication, primarily holding the underlying securities. While the fund may use derivatives for efficient portfolio management (EPM), such use is described as exceptional and not central to the investment strategy. There is no evidence of synthetic replication, embedded derivatives, significant leverage, or other features that would introduce complexity beyond the standard UCITS framework. The risks disclosed (market, liquidity, concentration, emerging markets, smaller companies) are typical for equity ETFs and do not indicate structural complexity. The fund does not hold complex bonds, contingent convertible securities, or employ complex indices. Therefore, based on the available information, this UCITS ETF meets the criteria for non-complex classification under MiFID II[1]."
}