{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The Franklin FTSE Asia ex China ex Japan UCITS ETF is a UCITS-compliant ETF that invests primarily in equities of medium and large capitalization companies in Asian markets excluding China and Japan. It uses physical replication by holding all benchmark securities in similar proportions to their weighting in the benchmark index, the FTSE Asia ex Japan ex China Index -NR. The ETF may use derivatives only for hedging and efficient portfolio management (EPM) purposes, such as managing currency risk or inflows/outflows, with limited impact on the risk-return profile. There is no indication of embedded derivatives, synthetic replication, leverage beyond UCITS limits, or complex structured products such as CLOs. The ETF targets retail investors with basic investment knowledge and provides transparent information about its structure, risks, and benchmark. The risk profile reflects market volatility but does not imply 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. The ETF does not embed derivatives integral to its strategy, nor does it have features such as leverage or capital protection structures that would increase complexity. Therefore, it meets the criteria for non-complex classification under MiFID II. This assessment aligns with ESMA guidance and CESR analysis that physical replication and limited derivative use for EPM support a non-complex classification, while synthetic replication or embedded derivatives would lead to complexity. No comprehension alert is required in the PRIIPs KID for this ETF."
}