{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The HSBC FTSE EPRA NAREIT DEVELOPED UCITS ETF is a UCITS-compliant ETF that aims to track the FTSE EPRA NAREIT Developed Index by investing primarily in the shares of companies in the index. It uses physical replication by holding underlying securities or equivalent instruments such as depositary receipts. The ETF may use derivatives only for efficient portfolio management (EPM) purposes, such as managing risk and costs, with derivative exposure limited (up to 10% in total return swaps and contracts for difference, but not exceeding 5% in any one type). This limited derivative use for EPM does not constitute integral use of derivatives to achieve the investment objective, thus derivatives are not considered inherent to the strategy. The ETF may engage in securities lending up to 30% of assets, but this is managed within UCITS rules and does not dominate the risk profile. There is no significant leverage beyond UCITS limits. The underlying index is transparent and well-documented. The risk profile is high due to market volatility (risk category 6/7), but this reflects market risk, not structural complexity. The ETF does not embed derivatives or structured products such as CLOs. Therefore, under MiFID II Article 25(4)(a)(iv) and Article 57 of the Delegated Regulation, this UCITS ETF is classified as non-complex. This aligns with ESMA and CESR guidance that UCITS ETFs using physical replication and limited EPM derivative use are non-complex, and no appropriateness assessment or comprehension alert is required for retail investors. The ETF's structure and risks are straightforward and understandable by retail investors with basic knowledge, supporting the non-complex classification."
}