{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The Vanguard ESG Emerging Markets All Cap UCITS ETF employs a passive management approach through physical acquisition of securities, tracking the FTSE Emerging All Cap Choice Index by investing in all constituent securities or using sampling where full replication is impracticable. The fund may use derivatives only for risk reduction or cost management, which is consistent with efficient portfolio management (EPM) and does not constitute integral use of derivatives to achieve investment objectives. The replication method is physical, not synthetic, which supports non-complex classification. The fund is UCITS compliant, subject to strict regulatory requirements ensuring diversification, liquidity, and transparency. There is no significant leverage beyond UCITS limits, no embedded derivatives or structured products, and the underlying index is transparent and straightforward. Although derivatives may be used for hedging or income generation, their use is limited and does not materially impact the risk-return profile. Securities lending is not mentioned as a dominant feature. The risk profile reflects market volatility typical of emerging markets but does not imply structural complexity. According to MiFID II Article 254 and Delegated Regulation EU 2017/565 Article 57, and ESMA guidelines, such a UCITS ETF with physical replication, limited derivative use for EPM, and transparent structure is classified as non-complex. This aligns with Janus Henderson's statement that all UCITS funds are automatically non-complex unless specific complex features are present, and ESMA's view that synthetic or structured UCITS ETFs are complex, which does not apply here. Therefore, the ETF does not embed complex features such as swaps, leverage, or structured products like CLOs, and the investor can understand the risks and payoff with basic knowledge, fulfilling the criteria for non-complex classification under MiFID II."
}