{
    "ucits": true,
    "type": "ETC",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "None",
    "classification": "non-complex",
    "supporting_data": "The product is a UCITS-eligible ETC, which is generally presumed non-complex under MiFID II[1]. It uses physical replication, holding allocated physical gold as its underlying asset, and does not use derivatives for investment purposesu2014only for efficient portfolio management (EPM) such as daily currency hedging, which is disclosed and does not materially alter the risk-return profile. There is no leverage, no embedded derivatives, no swaps, and no inverse or complex features. The structure, risks, and costs are transparent and straightforward, and the product is intended for retail investors with basic knowledge. The risk indicator is medium (4/7), reflecting market risk, not structural complexity. All costs and risks are clearly disclosed in the KID. No features trigger the MiFID II complexity criteria under Article 57 of Delegated Regulation 2017/565 or the structured UCITS exception. Therefore, the product is non-complex."
}