{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "None",
    "classification": "non-complex",
    "supporting_data": "The FlexSharesu00ae Listed Private Equity UCITS ETF is a UCITS-compliant ETF, which is automatically presumed non-complex under MiFID II unless specific features introduce complexity[1]. The ETF uses physical replication, investing directly in the component securities of its benchmark index, which is transparent and straightforward for retail investors to understand. Derivatives are used only for efficient portfolio management (EPM) purposesu2014such as risk reduction, cost minimization, or income generationu2014and are not central to the investment strategy. There is no evidence of significant leverage, synthetic replication, embedded derivatives, or other complex features such as contingent convertible bonds, swaps, or complex indices. The ETFu2019s structure, risks, and objectives are clearly disclosed, and the risks highlighted (liquidity, currency, valuation, private equity) are typical of equity ETFs and do not indicate structural complexity. Therefore, the ETF meets all criteria for non-complex classification under MiFID II Article 25(4) and Article 57 of the Delegated Regulation[1]."
}