{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Use of derivatives for efficient portfolio management; no synthetic replication; no embedded derivatives or structured products",
    "classification": "non-complex",
    "supporting_data": "The Global X Telemedicine & Digital Health UCITS ETF is a UCITS-compliant ETF that primarily invests in equity securities physically replicating the Solactive Telemedicine & Digital Health Index. It uses derivatives only for efficient portfolio management purposes such as hedging currency risk and managing inflows/outflows, including total return unfunded OTC swaps and exchange-traded equity futures, but these are not integral to the investment objective. The ETF does not employ synthetic replication, leverage beyond UCITS limits, or embedded derivatives such as structured products. Securities lending is used but managed within UCITS rules with collateral requirements, and does not dominate the risk profile. The underlying index is transparent and straightforward, focusing on telemedicine and digital health companies. The risk profile reflects market volatility and sector concentration but does not imply structural complexity. According to MiFID II Article 25(4)(a)(iv), UCITS ETFs are presumed non-complex. The use of derivatives limited to efficient portfolio management with minimal impact on risk-return profile supports this classification. ESMA guidance and CESR analysis confirm that physical replication and limited derivative use for EPM do not automatically render an ETF complex. Therefore, this ETF is classified as non-complex under MiFID II appropriateness rules[1][2][4]."
}