{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Currency hedging via FX forwards, ESG screening criteria",
    "classification": "non-complex",
    "supporting_data": "The iShares MSCI Japan SRI EUR Hedged UCITS ETF is a UCITS-compliant ETF that aims to replicate the MSCI Japan SRI 100% Hedged to EUR Index by physical replication of the underlying equity securities and use of FX forward contracts for currency hedging. The derivatives used (FX forwards) are employed solely for efficient portfolio management (EPM) to hedge currency risk, which is consistent with non-complex classification under MiFID II Article 254 and Delegated Regulation EU 2017/565 Article 57. The ETF does not use synthetic replication or swaps, nor does it embed derivatives integral to the investment objective beyond EPM. There is no significant leverage beyond UCITS limits. The index tracked is transparent and based on ESG criteria, which does not inherently increase complexity. Securities lending is present but managed within UCITS rules and does not dominate the risk profile. The risk profile is moderate (risk category 6/7) reflecting market volatility, not structural complexity. According to ESMA and CESR guidance, UCITS ETFs using physical replication and limited derivative use for EPM are generally non-complex. Therefore, this ETF is classified as non-complex under MiFID II. The presence of FX forwards for hedging does not trigger complexity as they are not central to the investment strategy but used for risk management. No embedded derivatives or structured products are held. The ETFu2019s structure and risks are understandable by retail investors with basic knowledge, fulfilling the ease of understanding criterion. Hence, no appropriateness test or comprehension alert is required for execution-only sales."
}