{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivatives, Swaps, Concentration Risk, Emerging Markets Risk, Currency Risk, Liquidity Risk",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is authorized under the UCITS Directive and is therefore automatically classified as non-complex under MiFID II Article 25(4)(a)(iv), regardless of the underlying investments or risk profile[1]. The ETF uses physical replication as its primary strategy, investing directly in the component securities of its benchmark index. However, the ETF may use financial derivative instruments (FDIs), including total return unfunded OTC swaps and exchange-traded equity futures, for investment purposes and to hedge currency risk. The use of derivatives is disclosed as a risk factor but is not central to the ETF's investment objective, which is to track a transparent, equity-based index. The ETF may also engage in securities lending, but this is for efficient portfolio management and within UCITS limits. The ETF does not employ leverage beyond temporary borrowing limits allowed under UCITS. The risks highlighted in the KIIDu2014such as concentration in Internet of Things companies, emerging markets exposure, currency risk, and liquidity risku2014are typical of thematic equity ETFs and do not, by themselves, trigger a complex classification under MiFID II. The ETF's structure, objective, and risks are transparent and disclosed in a manner intended to be understandable to retail investors. There is no evidence of embedded derivatives, contingent convertible bonds, or other features that would automatically render the ETF complex. While ESMA has noted that synthetic ETFs and structured UCITS should be considered complex, this ETF is physically replicated and does not appear to be a structured UCITS as defined in Regulation (EU) No 583/2010[2]. Therefore, despite the use of derivatives for hedging and efficient portfolio management, the ETF remains non-complex under the UCITS presumption and current regulatory interpretation."
}