{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The Fidelity Emerging Markets Equity Research Enhanced UCITS ETF is a UCITS-compliant ETF investing primarily in emerging market equities, aiming for long-term capital growth. It uses physical replication by holding underlying equity securities, with derivatives used only for efficient portfolio management and currency hedging purposes, not as an inherent part of the investment strategy. The fund does not employ leverage beyond UCITS limits, nor does it embed derivatives such as swaps integral to its performance. The underlying benchmark is the MSCI Emerging Markets (Net Total Return) Index, a transparent and well-documented equity index. The ETF's structure and risks (market volatility, tracking error) are straightforward and understandable by retail investors with basic knowledge. According to MiFID II Article 254, Delegated Regulation EU 2017/565 Article 57, and ESMA guidelines, UCITS ETFs that use physical replication and derivatives only for EPM with minimal risk impact are classified as non-complex. There is no indication of complex features such as embedded derivatives, significant leverage, synthetic replication, or complex structured products like CLOs. Therefore, this ETF is classified as non-complex under MiFID II. This aligns with the general regulatory presumption that UCITS ETFs are non-complex unless specific complex features are present. Janus Henderson Investors also confirm that all UCITS funds are automatically non-complex under MiFID II. ESMA and CESR guidance support that physical replication ETFs with limited derivative use for EPM remain non-complex. Hence, no appropriateness assessment beyond standard disclosure is required for retail investors investing in this ETF."
}