{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivatives for efficient portfolio management and investment purposes, up to 10% in total return swaps and contracts for difference (not expected to exceed 5%); securities lending up to 30% of assets (not expected to exceed 25%)",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is authorized under the UCITS Directive and is therefore automatically classified as non-complex under MiFID II Article 25(4)(a)(iv), regardless of underlying investments[1]. The ETF primarily uses physical replication to track its index, which is transparent and straightforward. While the ETF may use derivatives (including up to 10% in total return swaps and contracts for difference, though not expected to exceed 5%) and engage in securities lending (up to 30% of assets, not expected to exceed 25%), these activities are for efficient portfolio management and are not central to the investment objective. The use of derivatives is limited, well-disclosed, and within UCITS regulatory limits, which does not overturn the UCITS presumption of non-complexity. There is no evidence of significant leverage, embedded derivatives, or other features that would make the structure or risks difficult for a retail investor with basic knowledge to understand. The index tracked is transparent, and the ETFu2019s risks (market, liquidity, counterparty, etc.) are clearly disclosed in the KIID. Therefore, despite some derivative use and securities lending, the ETF remains non-complex under MiFID II."
}