{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Active management, use of derivatives for risk management, emerging markets exposure, ESG integration, multi-factor quantitative model, securities lending, operational and liquidity risks, counterparty risk from derivatives, sustainability risk, China and Stock Connect risks",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is actively managed, invests primarily in equity securities of emerging market companies, and may use derivatives for efficient portfolio management (EPM) purposes to help manage risks. The ETF references the MSCI Emerging Markets Index as a performance comparator but is not required to track it closely. The use of derivatives is limited to EPM (e.g., hedging, managing inflows/outflows, reducing transaction costs) and is not central to the investment strategy. The ETF does not use significant leverage, synthetic replication, or embedded derivatives. The structure and risks (market, operational, liquidity, counterparty, sustainability, China, and Stock Connect) are disclosed and are typical for actively managed equity UCITS ETFs. The ETF is UCITS-compliant, which under MiFID II Article 25(4)(a)(iv) is generally presumed non-complex unless it is a 'structured UCITS' (which this is not, as it does not employ algorithm-based payoffs or similar complex features). The use of derivatives for EPM does not automatically make the ETF complex under MiFID II, as the risks introduced are ancillary and well-managed within UCITS rules. The ETFu2019s risk profile is elevated due to emerging markets exposure and active management, but this reflects market risk, not structural complexity. All relevant risks are clearly disclosed in the KID. Therefore, despite some complex features (active management, EPM derivative use, securities lending), the ETF remains non-complex under MiFID II for UCITS ETFs that are not 'structured UCITS' and do not embed complex derivatives or leverage[1][2]."
}