{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivative use for currency hedging, multi-factor index methodology, securities lending",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is physically replicated, investing directly in the underlying equities of its benchmark index. While it uses derivatives (FX forwards) for currency hedging, this use is ancillary and not central to the investment objectiveu2014derivatives are employed to reduce currency risk, not to replicate the index or amplify returns. The ETF does not use leverage beyond UCITS limits, does not employ swaps or inverse strategies, and does not embed complex payoffs or contingent convertible bonds. The index methodology is multi-factor (momentum, quality, value, low volatility, size), which introduces some complexity in index construction but does not, by itself, make the ETF complex under MiFID II. Securities lending is conducted within UCITS limits and is a secondary activity. The structure, risks, and objectives are transparent and disclosed in the KID. Under MiFID II, all UCITS are automatically non-complex unless they are 'structured UCITS' with algorithm-based payoffs or similar complex features, which this ETF is not[1]. The use of derivatives for efficient portfolio management (EPM), such as currency hedging, does not automatically trigger a complex classification if the impact on the risk-return profile is minimal and well-disclosed, as is the case here. The ETFu2019s risks are market volatility, tracking error, and counterparty risk from derivatives and securities lending, but these are standard for equity ETFs and do not introduce structural complexity that would be difficult for a retail investor with basic knowledge to understand. Therefore, despite some nuanced features, the ETF remains non-complex under MiFID II[1]."
}