{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "None identified",
    "classification": "non-complex",
    "supporting_data": "The Sub-Fund is a UCITS ETF, which is 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 Sub-Fund invests primarily in equity securities of Japanese companies, with no indication of synthetic replication, significant derivative use, leverage, or embedded options. Derivatives are used only for efficient portfolio management (EPM), not as a core part of the investment strategy, and the KID does not indicate that these derivative exposures introduce material counterparty, collateral, or complexity risks. The Sub-Fund is actively managed and references a transparent, well-documented equity index (MSCI Japan Investable Market Index). There is no evidence of complex features such as contingent convertible bonds, swaps, or complex indices. The structure, risks, and investment objective are straightforward and should be understandable to retail investors with basic knowledge. Therefore, the Sub-Fund meets all criteria for non-complex classification under MiFID II[1]."
}