{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Use of derivatives for efficient portfolio management and limited total return swaps exposure",
    "classification": "non-complex",
    "supporting_data": "The HSBC NASDAQ Global Climate Tech UCITS ETF is a UCITS-compliant ETF that aims to track the NASDAQ CTA Global Climate Technology Index using primarily physical replication by investing in shares of the index constituents. The ETF may use derivatives, including total return swaps and contracts for difference, but only up to 10% of its assets, with expected exposure not exceeding 5%, and mainly for efficient portfolio management purposes such as risk and cost management. Securities lending is also used but limited to a maximum of 30% of assets, typically not exceeding 25%. The ETF does not employ significant leverage beyond UCITS limits, nor does it embed derivatives integral to its investment objective or use synthetic replication as the main strategy. The risk factors disclosed include counterparty risk and derivatives risk, but these are managed within UCITS regulatory frameworks and are limited in scale. According to MiFID II Article 254 and Delegated Regulation EU 2017/565 Article 57, UCITS ETFs are presumed non-complex unless they embed derivatives as a core strategy (e.g., synthetic replication) or have complex features such as leverage beyond UCITS limits or structured products with embedded options. This ETFu2019s limited derivative use for efficient portfolio management and physical replication support a non-complex classification. The ETFu2019s structure and risks are transparent and understandable to retail investors with basic knowledge, consistent with MiFID II criteria. Therefore, despite some derivative use, the ETF does not meet the criteria for complexity under MiFID II and ESMA guidelines, and no PRIIPs comprehension alert is required."
}