{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "None",
    "classification": "non-complex",
    "supporting_data": "The UBS (Irl) ETF plc - MSCI Australia UCITS ETF is a UCITS-compliant, physically replicated ETF tracking a transparent equity index (MSCI Australia 100% hedged to CHF Index). It holds the underlying securities in the same proportions as the index, with no evidence of synthetic replication, embedded derivatives, or significant use of derivatives for purposes other than efficient portfolio management (EPM) such as currency hedging. The fund may use derivatives for risk reduction or cost efficiency, but these are not central to the investment strategy and do not introduce material counterparty or collateral risk. The structure, risks, and payoff are straightforward and easily understood by retail investors with basic knowledge. There is no significant leverage, no embedded derivatives, and no complex features such as contingent convertible bonds or swaps. The index is transparent and the fundu2019s documentation is comprehensive and accessible. Under MiFID II, all UCITS are automatically non-complex unless they employ complex portfolio management techniques or structured features, which is not the case here[1]. The use of derivatives for hedging does not, in this context, trigger a complex classification, as they are limited to EPM and do not materially alter the risk-return profile or introduce opacity[1]. Securities lending is permitted but, if well-managed within UCITS rules, does not make the ETF complex. The high risk category (6/7) reflects market volatility of equities, not structural complexity. Therefore, the ETF meets all criteria for non-complex classification under MiFID II Article 25(4) and Article 57 of the Delegated Regulation."
}