{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivatives for efficient portfolio management, limited use of swaps, securities lending",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is physically replicated, tracking a transparent, well-documented equity index (MSCI Emerging Markets). While it may use derivatives (including up to 10% in total return swaps and contracts for difference, though not expected to exceed 5%) for efficient portfolio management (EPM) and may engage in securities lending (up to 30% of assets, not expected to exceed 25%), these features are ancillary and do not fundamentally alter the risk-return profile or make the structure opaque. The use of derivatives is limited, disclosed, and in line with UCITS rules for risk management, not for speculative purposes or to achieve leveraged returns. The ETF does not use significant leverage, does not embed complex options or structured payoffs, and does not hold contingent convertible bonds or other inherently complex securities. The risks disclosed (emerging markets risk, currency risk, tracking error, counterparty risk from derivatives and securities lending, liquidity risk) are typical for equity ETFs and do not introduce structural complexity beyond what a retail investor with basic knowledge could reasonably understand. The ETF is UCITS-compliant, which under MiFID II generally presumes non-complexity unless specific complex features are present[1]. Here, the limited and well-disclosed use of derivatives and securities lending does not override the UCITS presumption of non-complexity, as these are not central to the investment objective and do not make the product difficult to understand for the target retail investor[1]. There is no evidence of embedded derivatives, complex indices, or other features that would trigger a complex classification under Article 57 of the MiFID II Delegated Regulation. Therefore, the ETF is classified as non-complex."
}