{
    "ucits": true,
    "type": "ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": "Derivatives for efficient portfolio management and index tracking, up to 10% in total return swaps and contracts for difference, securities lending up to 30% of assets",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is physically replicating a transparent, well-diversified equity index (FTSE EPRA NAREIT Developed Index). While it may use derivatives for efficient portfolio management and to gain exposure to index constituents when direct investment is not possible or practical, such use is limited (not expected to exceed 5% in swaps/CFDs, with a hard cap at 10%). Securities lending is permitted but capped at 30% of assets and not expected to exceed 25%. There is no significant leverage beyond temporary UCITS borrowing limits. The structure, risks, and objectives are straightforward and disclosed. The ETF does not embed complex derivatives, offer capital protection, or track an opaque index. 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 limited and disclosed use of derivatives for risk and cost management does not, under current regulatory practice, override the UCITS presumption of non-complexity, provided the risks are transparent and the strategy remains passive and index-tracking[1]. Therefore, despite some derivative and securities lending activity, the ETF is classified as non-complex under MiFID II."
}