{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The HSBC MSCI Pacific ex Japan UCITS ETF is a UCITS-compliant ETF, which under MiFID II is generally presumed non-complex due to the strict regulatory framework governing UCITS funds[1]. The ETF aims to physically replicate the MSCI Pacific ex Japan Index by investing in shares of companies in the index, which supports a non-complex classification as physical replication is transparent and straightforward for retail investors to understand[2].The ETF may use derivatives only for efficient portfolio management (EPM) purposes, such as managing risk and costs, and this use is limited (up to 10% of assets in total return swaps and contracts for difference, but not expected to exceed 5%), which does not make derivatives integral to the investment objective but rather ancillary for risk management. According to MiFID II rules and ESMA guidance, such limited derivative use for EPM with minimal impact on risk-return profile does not automatically trigger complexity[2][3].The ETF engages in securities lending up to 30% of assets (not expected to exceed 25%), which introduces some counterparty risk but is well-managed under UCITS rules and does not by itself render the ETF complex[2].There is no significant leverage beyond UCITS limits, no embedded derivatives, and the underlying index is transparent and straightforward (MSCI Pacific ex Japan Index), which further supports non-complexity[2].The risk profile is high (category 6 out of 7) due to market volatility, but market risk alone does not make an ETF complex under MiFID II; complexity arises from structural features that are difficult to understand, which this ETF does not have[2][3].Therefore, based on the MiFID II complexity assessment framework, including Article 254 of MiFID II, Delegated Regulation EU 2017/565 Article 57, and ESMA guidelines, this UCITS ETF is classified as non-complex. It uses physical replication, limited derivatives for EPM only, no leverage beyond UCITS limits, and has a transparent structure and risks understandable by retail investors with basic knowledge[1][2][3]."
}