{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivative use for direct investment purposes, multi-factor index methodology, securities lending",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is physically replicated, investing primarily in equity securities to track a transparent, multi-factor index. While the fund may use financial derivative instruments (FDIs) for direct investment purposes, there is no evidence that derivatives are central to the investment strategy or that synthetic replication (e.g., total return swaps) is employed. The use of derivatives appears limited and not integral to achieving the fund's objective, which is typical for non-complex UCITS ETFs[1]. Securities lending is permitted but is a secondary activity, well-managed within UCITS rules, and does not dominate the risk profile. The index methodology, while multi-factor, is transparent and publicly documented, and the fund's structure and risks (market volatility, tracking error) are straightforward for retail investors with basic knowledge to understand. There is no significant leverage, embedded derivatives, or opaque features. Under MiFID II, UCITS are generally presumed non-complex unless specific features indicate otherwise, and no such features are present here that would override the UCITS presumption[1]. Therefore, despite the potential for limited derivative use and securities lending, the ETF remains non-complex under MiFID II."
}