{
    "ucits": true,
    "type": "ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": "Derivatives for efficient portfolio management and investment purposes, including up to 10% in total return swaps and contracts for difference; securities lending up to 30% of assets; exposure to depositary receipts and other funds; tracking error and market risk.",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is physically replicated, aiming to track the MSCI Pacific ex Japan Index by holding the underlying securities. While it may use derivatives (including up to 10% in total return swaps and contracts for difference) for efficient portfolio management and to gain exposure when direct investment is not possible, this use is ancillary and not central to the fund's strategy. Securities lending is permitted but capped and managed within UCITS rules. The fund does not employ leverage beyond temporary borrowing limits, does not use inverse strategies, and does not embed complex derivatives or structured products. The risks disclosed (derivatives risk, counterparty risk, liquidity risk, operational risk) are typical for UCITS ETFs and do not introduce structural complexity that would make the product difficult for a retail investor with basic knowledge to understand. The fund is UCITS-compliant, listed, and redeemable daily, with comprehensive, publicly available information. Under MiFID II, all UCITS are automatically non-complex unless they are structured UCITS (which provide algorithm-based payoffs or similar complex features)u2014this fund does not meet that definition[1]. The use of derivatives for risk and cost management, within the stated limits, does not override the UCITS presumption of non-complexity, as the structure, risks, and objectives remain transparent and straightforward for the average retail investor[1]. Therefore, despite some derivative usage and securities lending, the fund is classified as non-complex under MiFID II."
}