{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivative use for efficient portfolio management; Active management with enhanced index strategy; Exposure to emerging markets with potential counterparty risk",
    "classification": "non-complex",
    "supporting_data": "The asset is a UCITS ETF, which under MiFID II is generally presumed non-complex due to strict regulatory requirements ensuring diversification, liquidity, and transparency. The ETF pursues an actively managed strategy aiming to outperform the MSCI Emerging Market Index by selecting equities primarily in emerging markets, including China A-Shares via Stock Connect. It may use financial derivative instruments for efficient portfolio management purposes only, not as an inherent element of the investment strategy, which aligns with the MiFID II rule that limited derivative use for EPM does not automatically trigger complexity. The replication method is physical, holding underlying securities rather than synthetic replication, which supports non-complex classification. There is no indication of embedded derivatives, significant leverage, or complex structured products such as CLOs. The ETF's structure and risks (market volatility, tracking error) are straightforward and understandable by retail investors with basic knowledge. Although emerging markets carry higher market and political risks, these do not constitute structural complexity under MiFID II. The ETF does not embed swaps integral to its strategy, nor does it have features like capital protection or significant securities lending that would increase complexity. Therefore, based on MiFID II Article 254, Delegated Regulation EU 2017/565 Article 57, and ESMA guidelines, this UCITS ETF is classified as non-complex."
}