{
    "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 250 UCITS ETF is a UCITS-compliant ETF that aims to track the FTSE 250 Index by investing primarily in the shares of the companies in the index, generally in the same proportion as the index. It uses physical replication, holding underlying securities rather than synthetic replication. The ETF may use derivatives only for efficient portfolio management (EPM) purposes, such as managing risk and costs, and derivative exposure is limited to a maximum of 10% of assets, typically not exceeding 5%. This limited derivative use is for hedging or cost management and does not form an integral part of the investment strategy, so derivatives are not considered inherent to the product's risk profile. The fund may engage in securities lending up to 30% of assets, but this is well-managed under UCITS rules and does not dominate the risk profile. There is no significant leverage beyond UCITS limits, no embedded derivatives, and the underlying index is transparent and straightforward. The risk profile is high due to market volatility (risk category 6), but this reflects market risk, not structural complexity. According to MiFID II Article 25(4)(a)(iv) and Article 57 of the Commission Delegated Regulation, UCITS ETFs using physical replication and limited derivative use for EPM are presumed non-complex. The ETF does not embed derivatives or structured products such as CLOs, which would trigger complexity. Therefore, the ETF is classified as non-complex under MiFID II. This aligns with ESMA guidance that physical replication ETFs with limited EPM derivative use and transparent indices are non-complex, while synthetic or structured UCITS ETFs would be complex. No comprehension alert is required in the PRIIPs KID for this ETF."
}