{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "None",
    "classification": "non-complex",
    "supporting_data": "The L&G Pharma Breakthrough UCITS ETF is a UCITS-compliant, physically replicated ETF that primarily invests directly in the securities represented in its benchmark index. It may use financial derivative instruments (FDIs) for efficient portfolio management, but these are not central to its investment objective or strategy. The ETF does not use leverage beyond UCITS limits, does not employ swaps or synthetic replication, and does not have embedded derivatives or complex features such as contingent convertible bonds, structured payoffs, or algorithm-based returns. The index tracked is transparent and the risks disclosed (e.g., market, currency, liquidity, issuer) are typical for equity ETFs and do not introduce structural complexity. The ETFu2019s structure, risks, and objectives are straightforward and can be understood by retail investors with basic knowledge. Under MiFID II, all UCITS are automatically non-complex unless they employ complex portfolio management techniques or structured features that make the product difficult to understandu2014neither of which applies here[1]. The use of derivatives for efficient portfolio management, if any, is limited and does not alter the risk-return profile in a way that would trigger a complex classification under Article 57 of the MiFID II Delegated Regulation. There is no evidence of securities lending significantly increasing risk or opacity. Therefore, the ETF is classified as non-complex."
}