{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "None",
    "classification": "non-complex",
    "supporting_data": "The Rize Cybersecurity and Data Privacy UCITS ETF is a UCITS-compliant, passively managed ETF that primarily invests in the underlying securities of its benchmark index using physical replication. The fund may use financial derivative instruments (FDIs) for efficient portfolio management (EPM), but there is no evidence that derivatives are integral to the investment strategy or that the ETF uses synthetic replication, swaps, or leverage beyond UCITS limits. The ETF's structure, risks, and objectives are transparent and straightforward, and it does not hold complex bonds, structured products, or contingent convertible bonds. The ETF is listed and traded on stock exchanges, providing frequent liquidity. All these factors align with the MiFID II presumption that UCITS ETFs are non-complex, provided they do not employ complex strategies or hold complex underlying assets[1][2]. The use of derivatives for EPM, if limited and well-disclosed, does not automatically trigger a complex classification under MiFID II, especially when the risks introduced are negligible and the structure remains easy for retail investors to understand[1][2]. There is no indication of embedded derivatives, complex indices, or other features that would make the ETF complex under Article 57 of the MiFID II Delegated Regulation."
}