{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The L&G Cyber Security UCITS ETF is a UCITS-compliant ETF that primarily invests physically in the underlying shares of companies in the cyber security sector, tracking a transparent index (the ISE Cyber Securityu00ae UCITS Index Net Total Return). It uses physical replication by holding the index constituents in similar proportions, with no indication of synthetic replication or significant use of derivatives integral to the investment objective. The ETF may use financial derivative instruments (FDIs) only for limited purposes such as efficient portfolio management, but these are not central to the strategy and do not introduce complex risks like counterparty or collateral risk. There is no mention of embedded derivatives, leverage beyond UCITS limits, or complex structured products such as CLOs. The ETF's structure and risks (market volatility, tracking error) are straightforward and understandable by retail investors with basic knowledge. The index tracked is transparent and publicly available. Securities lending, if any, is managed within UCITS rules and does not dominate the risk profile. The risk rating is high (7/7) due to market volatility inherent in the sector, not due to structural complexity. According to MiFID II Article 25(4)(a)(iv) and Article 57 of the Delegated Regulation, UCITS ETFs that physically replicate transparent indices and do not embed derivatives integral to the strategy are presumed non-complex. This ETF meets these criteria and thus is classified as non-complex under MiFID II. This aligns with ESMA and CESR guidance that physical replication and limited derivative use for EPM do not trigger complexity. Therefore, no appropriateness assessment beyond standard disclosure is required for retail investors investing in this ETF."
}