{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivatives, Swaps, Efficient Portfolio Management (EPM) with derivatives, Securities Lending, Emerging Markets Risk, Counterparty Risk",
    "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), unless it is a structured UCITS or fails the Article 57 criteria[1]. The fund uses derivatives (including up to 10% in total return swaps and contracts for difference, though typically less than 5%) for efficient portfolio management (EPM) and investment purposes, not as a core strategy to achieve its objective. The ETF primarily uses physical replication to track its index, holding the underlying securities directly, which supports transparency and ease of understanding. Securities lending is permitted up to 30% of assets (typically less than 25%), introducing some counterparty risk, but this is a secondary feature and managed within UCITS rules. The fund does not use significant leverage beyond temporary borrowing limits. The underlying index is transparent and the fundu2019s structure, risks, and objectives are clearly disclosed. While the use of derivatives and securities lending introduces some complexity and counterparty risk, these features are limited, well-disclosed, and do not dominate the risk profile or make the product difficult for a retail investor with basic knowledge to understand. There is no evidence of embedded derivatives, contingent convertible bonds, or other features that would automatically trigger a complex classification. Therefore, despite some derivative and swap usage, the ETF remains non-complex under MiFID II for UCITS[1]. However, if derivative use were central to the strategy (e.g., synthetic replication) or if the fund held complex structured products like CLOs, a complex classification might apply, but this is not the case here."
}