{
    "ucits": true,
    "type": "ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": "Derivatives, Swaps, Efficient Portfolio Management (EPM) use",
    "supporting_data": "The ETF is UCITS-compliant and primarily uses physical replication to track its index, which supports a non-complex classification. However, the ETF may invest up to 10% of its assets in total return swaps and contracts for difference, and may use derivatives for efficient portfolio management (EPM) purposes. While the use of derivatives is limited and not central to the investment objective, any derivative exposureu2014especially swapsu2014introduces counterparty risk and potential complexity. The ETF also engages in securities lending (up to 30% of assets), but this is a secondary feature and well within UCITS rules. The underlying index is transparent and the ETFu2019s structure is straightforward, but the presence of swaps and other derivatives means the product does not fully meet the criteria for automatic non-complexity under MiFID II Article 57, as instruments embedding derivatives are excluded from the non-complex category[1][2]. The ETFu2019s risk profile is driven by market volatility and tracking error, not by structural complexity, but the use of swaps and derivatives for EPM means the product should be assessed for complexity on a case-by-case basis, with particular attention to whether a retail investor can easily understand the associated risks (e.g., counterparty risk from swaps).",
    "classification": "complex"
}