{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Active management, use of derivatives for risk reduction and cost management, securities lending, moderate risk profile, no embedded derivatives or structured products",
    "classification": "non-complex",
    "supporting_data": "The fund is a UCITS ETF, which is generally presumed non-complex under MiFID II[1]. It is actively managed without reference to a benchmark, but its primary investments are in other UCITS funds and UCITS ETFs, not in complex structured products or derivatives central to the strategy. The fund may use financial derivative instruments for risk reduction, cost management, and income generation, but this use is described as ancillary (not central to the investment objective) and within the regulatory limits for UCITS. Securities lending is permitted but is a secondary feature, well-managed within UCITS rules. The fund does not use significant leverage, does not embed derivatives, and does not invest in complex indices or structured products like CLOs. The risk profile is moderate (rated 4 out of 7), reflecting market volatility rather than structural complexity. The structure, risks, and objectives are transparent and can be understood by retail investors with basic knowledge. Therefore, despite active management and limited derivative use, the fund does not exhibit features that would override the UCITS presumption of non-complexity under MiFID II[1]."
}