{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Use of derivatives for risk management; active management without benchmark; investment in other funds including UCITS ETFs and eligible commodities; securities lending",
    "classification": "non-complex",
    "supporting_data": "The fund is a UCITS ETF, which under MiFID II is generally presumed non-complex due to strict regulatory requirements ensuring diversification, liquidity, and transparency. The fund is actively managed without reference to a benchmark and invests predominantly in other UCITS funds, UCITS ETFs, and eligible exchange traded commodities, maintaining a conservative risk profile. It uses derivatives only for risk reduction, cost efficiency, and income generation, which aligns with efficient portfolio management (EPM) and does not constitute integral use of derivatives for replication or leverage. Securities lending is employed but managed within UCITS rules with collateral requirements, not dominating the risk profile. There is no indication of synthetic replication or embedded derivatives such as swaps integral to the investment objective. The replication method is physical through underlying UCITS ETFs and funds. The fund's structure and risks are transparent and understandable to retail investors with basic knowledge. No significant leverage or complex features like contingent convertible bonds or structured products are present. Therefore, according to MiFID II Article 254, Delegated Regulation EU 2017/565 Article 57, and ESMA guidelines, this UCITS ETF is classified as non-complex."
}