{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Currency hedging via forward contracts, securities lending for efficient portfolio management",
    "classification": "non-complex",
    "supporting_data": "The fund is a UCITS ETF, which is automatically non-complex under MiFID II unless it is a structured UCITS or fails the Article 57 criteria[1]. The ETF uses physical replication to track a transparent, rule-based equity index. Derivatives (forward foreign exchange contracts) are used solely for currency hedging to neutralize JPY/USD exposure, not for synthetic replication or to achieve leveraged/inverse returns. Securities lending is permitted but only for efficient portfolio management, within UCITS limits, and does not dominate the risk profile. There is no significant leverage, no embedded derivatives, and no complex or opaque index. The structure, risks (market, currency, tracking error, counterparty from hedging and securities lending), and objectives are clearly disclosed and should be understandable to a retail investor with basic knowledge. The use of derivatives is limited to hedging and does not introduce material complexity or opacity that would override the UCITS presumption of non-complexity, provided the risks are well-disclosed and managed within regulatory limits[1]. The fund does not appear to be a structured UCITS as defined in Regulation (EU) No 583/2010. Therefore, it remains non-complex under MiFID II."
}