{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The asset is a UCITS ETF (First Trust Eurozone AlphaDEXu00ae UCITS ETF) that aims to replicate the NASDAQ AlphaDEXu00ae Eurozone Index by holding equity securities in similar proportions to the index, primarily through physical replication. The fund's investment policy indicates it invests mainly in equities and may use depositary receipts only when direct investment is not possible, with a minor allocation to money market instruments and other eligible funds. There is no indication of synthetic replication or significant use of derivatives integral to the investment objective. The fund does not employ leverage beyond UCITS limits, nor does it embed derivatives or structured products such as CLOs. The risk profile is high (category 6/7) due to market volatility, not structural complexity. Charges and liquidity terms are standard, with no exit charges or complex features. According to MiFID II Article 254 and Delegated Regulation EU 2017/565 Article 57, UCITS ETFs using physical replication and limited or no derivative use for efficient portfolio management are presumed non-complex. The fund's transparent index, physical replication method, and straightforward structure support this classification. There is no evidence of complex features such as synthetic replication, embedded derivatives, significant leverage, or opaque index structures that would override the UCITS presumption. Therefore, under MiFID II, this UCITS ETF is classified as non-complex."
}