{
    "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 ETF is a UCITS-compliant, physically replicated fund tracking a transparent, well-documented equity index (FTSE EPRA/Nareit Developed Dividend+ Index). It invests primarily in listed real estate companies and REITs, with no direct exposure to physical real estate. The use of derivatives is limited to efficient portfolio management (EPM) purposes, such as risk reduction and cost management, and is not central to the investment strategy. Securities lending is conducted within UCITS limits and does not dominate the risk profile. The structure, risks (market volatility, sector concentration), and investment objective are straightforward and easily understood by retail investors with basic knowledge. There is no significant leverage, no embedded derivatives, and no complex features such as contingent convertible bonds or swaps. The ETF does not track a complex or opaque index, and all relevant information is publicly available in a clear, accessible format. Therefore, the ETF meets all criteria for non-complex classification under MiFID II Article 25(4)(a)(iv) and Article 57 of the Delegated Regulation[1][2]."
}