{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivatives for efficient portfolio management, limited use of total return swaps and contracts for difference, securities lending",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is physically replicating the FTSE 100 Index, holding the underlying shares in generally the same proportion as the index. While it may use derivatives for efficient portfolio management (EPM) and may invest up to 10% of assets in total return swaps and contracts for difference (not expected to exceed 5%), this use is limited and not central to the investment objective. Securities lending is permitted up to 30% of assets (not expected to exceed 25%), but this is a secondary feature and managed within UCITS rules. The ETF does not use significant leverage beyond UCITS limits, does not embed complex derivatives, and does not track a complex or opaque index. The structure, risks, and investment objective are transparent and straightforward for a retail investor with basic knowledge. Under MiFID II, UCITS are generally presumed non-complex, and the limited, well-disclosed use of derivatives for EPM does not, in this case, override that presumption, as the risks introduced (counterparty, collateral) are minimal and well-managed, and the productu2019s payoff and risks remain easy to understand[1]. The ETF does not exhibit features that would typically trigger a complex classification under Article 57 of the MiFID II Delegated Regulation (e.g., no embedded complex options, no contingent convertibles, no significant synthetic exposure, no complex indices). Therefore, despite the presence of some derivative usage and securities lending, the ETF remains non-complex for MiFID II purposes."
}