{
    "ucits": true,
    "type": "ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": "None",
    "classification": "non-complex",
    "supporting_data": "The SPDR Russell 2000 U.S. Small Cap UCITS ETF is a UCITS-compliant, physically replicated ETF tracking a transparent, well-documented equity index. It primarily invests in the underlying securities of the index, using an optimization strategy only to manage practical constraints, not to introduce complex risk exposures. The fund may use derivatives for efficient portfolio management (EPM), but such use is limited, incidental, and not central to the investment objectiveu2014consistent with UCITS rules and MiFID II guidance for non-complex classification. There is no evidence of synthetic replication, significant leverage, embedded derivatives, or other features that would introduce counterparty risk, complex payoffs, or opacity. The risks disclosed (market, tracking error, liquidity, concentration, small-cap volatility) are inherent to the asset class and do not reflect structural complexity. The fundu2019s structure, objective, and risks are straightforward and can be understood by a retail investor with basic knowledge. Therefore, it meets all criteria for non-complex classification under MiFID II Article 25(4) and Article 57 of the Delegated Regulation[1]."
}