{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivative use for efficient portfolio management; no embedded derivatives or structured products; no leverage beyond UCITS limits",
    "classification": "non-complex",
    "supporting_data": "The abrdn Global Real Estate Active Thematics UCITS ETF is a UCITS-compliant ETF investing primarily in listed real estate equities and REITs, with at least 80% invested in constituents of the FTSE EPRA NAREIT Developed Net Index. It uses derivatives only for efficient portfolio management purposes such as managing cash flows and currency hedging, with expected very limited derivative usage overall. The replication method is physical, holding underlying securities rather than synthetic replication. There is no indication of embedded derivatives, leverage beyond UCITS limits, or complex structured products such as CLOs. The ETF targets a transparent index and applies ESG exclusions, enhancing transparency. The risk profile reflects market volatility typical of equity investments but does not imply structural complexity. According to MiFID II Article 25(4)(a)(iv) and Article 57 of the Commission Delegated Regulation, UCITS ETFs that do not embed derivatives as a core strategy and use derivatives only for EPM with minimal impact are classified as non-complex. ESMA guidance confirms that synthetic or structured UCITS ETFs or those investing in complex derivatives or structured products (e.g., CLOs) would be complex, but this ETF does not fall into those categories. Therefore, it is classified as non-complex under MiFID II and does not require an appropriateness assessment for non-advised sales."
}