{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Use of derivatives for risk reduction and currency hedging; no synthetic replication; no embedded derivatives or structured products",
    "classification": "non-complex",
    "supporting_data": "The fund is a UCITS ETF tracking the MSCI Australia 100% hedged to USD Index by holding essentially all shares of the index in the same proportions, indicating physical replication. It uses derivatives only for risk reduction, cost reduction, or generating additional capital or income, specifically currency forwards for hedging currency risk. The derivatives use is limited and for efficient portfolio management, with no indication that derivatives are integral to the investment objective or that synthetic replication is used. There is no leverage beyond UCITS limits, no embedded derivatives or structured products like CLOs, and the index tracked is transparent and straightforward. Securities lending is mentioned but managed within UCITS rules. The risk profile is moderate to high due to equity market volatility, not structural complexity. According to MiFID II Article 254 and Delegated Regulation EU 2017/565 Article 57, such a UCITS ETF with physical replication and limited derivative use for EPM is classified as non-complex. ESMA guidance confirms that synthetic or structured UCITS ETFs or those investing in complex derivatives or structured products (e.g., CLOs) would be complex, but this fund does not exhibit those features. Therefore, the fund is non-complex under MiFID II rules."
}