{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "None",
    "classification": "non-complex",
    "supporting_data": "The Vanguard LifeStrategyu00ae 40% Equity UCITS (EUR) Distributing ETF is a UCITS-compliant ETF, which is automatically classified as non-complex under MiFID II Article 25(4)(a)(iv), unless it is a structured UCITS or fails Article 57 criteria[1]. The fund invests primarily in other UCITS ETFs and collective investment schemes tracking indices, using physical replication. While the fund may use derivatives for risk reduction or cost efficiency, such use is ancillary and not central to the investment strategyu2014derivatives are not used for synthetic replication, leverage, or to achieve complex payoffs. The fund's structure, objectives, and risks (market, currency, liquidity) are transparent and typical for a diversified multi-asset UCITS ETF. There is no evidence of embedded derivatives, contingent convertible bonds, swaps, or other complex features that would trigger a complex classification. The fund's risk profile (rated 4/7) reflects market volatility, not structural complexity. Therefore, it meets all criteria for non-complex classification under MiFID II[1]."
}