{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "None",
    "classification": "non-complex",
    "supporting_data": "The WisdomTree Europe SmallCap Dividend UCITS ETF is a UCITS-compliant ETF, which is generally presumed non-complex under MiFID II unless it has features that make its structure, risks, or payoff difficult for retail investors to understand[1]. The ETF uses a passive management (indexing) approach, investing in a representative sample of the component securities of its index, which is a transparent, rule-based, fundamentally weighted equity index of European small-cap dividend-paying companies. There is no evidence of synthetic replication, significant use of derivatives (beyond efficient portfolio management, such as securities lending within UCITS limits), leverage beyond temporary borrowing, or embedded complex structures. The ETF does not hold contingent convertible bonds, swaps, or other instruments that would introduce counterparty, collateral, or complex payout risks. The risks disclosed (market, liquidity, currency, tracking error, counterparty from ancillary services, operational) are typical for physically replicated equity ETFs and do not indicate structural complexity. The ETF is listed, liquid, and provides comprehensive, publicly available information in line with UCITS requirements. No features were identified that would override the UCITS presumption of non-complexity under MiFID II Article 25(4)(a)(iv) and Delegated Regulation Article 57[1]."
}