{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The SPDR FTSE UK All Share UCITS ETF is a UCITS-compliant ETF that seeks to track the FTSE All-Share Index primarily through physical replication, holding the underlying securities approximately in the same weightings as the index. The fund may use derivatives only for efficient portfolio management (EPM) purposes, such as managing inflows/outflows or hedging currency risk, with limited impact on the risk-return profile. There is no indication of synthetic replication or embedded derivatives integral to the investment objective. Securities lending is used but limited to a maximum of 40% of net asset value and managed within UCITS rules, which does not automatically trigger complexity. The ETF does not employ significant leverage beyond UCITS limits. The underlying index is transparent and well-known. The risk profile reflects market volatility but not structural complexity. According to MiFID II Article 25(4)(a)(iv) and Article 57 of the Commission Delegated Regulation, UCITS ETFs that physically replicate transparent indices and use derivatives only for EPM with minimal risk are classified as non-complex. ESMA guidance confirms that synthetic replication or embedded derivatives would lead to complexity, but this ETF does not exhibit such features. Therefore, the ETF is classified as non-complex under MiFID II appropriateness rules."
}