{
    "ucits": true,
    "type": "ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": "None",
    "classification": "non-complex",
    "supporting_data": "The Franklin FTSE Brazil UCITS ETF is a UCITS-compliant, physically replicated ETF tracking a transparent, well-documented equity index (FTSE Brazil 30/18 Capped Index). It invests directly in the underlying securities, and while it may use derivatives for efficient portfolio management (EPM) only, such use is not central to its investment objective and does not introduce significant counterparty or collateral risk. The ETF does not employ leverage, synthetic replication, or embedded derivatives, and its structure, risks, and performance are straightforward for retail investors to understand. All UCITS are automatically non-complex under MiFID II unless they are structured UCITS or use derivatives integrally, which is not the case here[1]. The ETFu2019s risk profile reflects market volatility and concentration in Brazilian equities, but these are standard risks for equity ETFs and do not constitute structural complexity under MiFID II. There is no evidence of complex features such as contingent convertible bonds, swaps, or complex indices. Therefore, the ETF meets all criteria for non-complex classification under MiFID II Article 25(4) and Delegated Regulation Article 57."
}