{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Limited use of total return swaps and contracts for difference (up to 10% of assets, not expected to exceed 5%); securities lending (up to 30% of assets, not expected to exceed 25%); passive management with physical replication of a transparent equity index; no significant leverage or embedded derivatives; no complex or opaque index.",
    "supporting_data": "The ETF is UCITS-compliant and primarily uses physical replication to track the FTSE Japan ESG Low Carbon Select Index, a transparent equity index. It may use derivatives (total return swaps and contracts for difference) for efficient portfolio management and to gain exposure to index constituents when direct investment is not possible or practical, but such use is limited (up to 10% of assets, not expected to exceed 5%). Securities lending is permitted (up to 30% of assets, not expected to exceed 25%) to generate additional income, subject to UCITS collateral requirements. The ETF does not employ significant leverage beyond temporary UCITS limits, does not embed complex derivatives, and does not track a complex or opaque index. The structure, risks (market, tracking error, liquidity, operational), and investment policy are clearly disclosed. The intended retail investor is assumed to have basic knowledge, and the risks, while present, are standard for equity ETFs and not structurally complex. The use of derivatives is ancillary, not central to the strategy, and does not dominate the risk profile. There is no evidence of contingent convertible bonds, complex indices, or other features that would make the ETF difficult for a retail investor to understand.",
    "classification": "non-complex"
}