{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivative use for efficient portfolio management, securities lending, exposure to emerging markets",
    "classification": "non-complex",
    "supporting_data": "The UBS (Lux) Fund Solutions u2013 MSCI Emerging Markets UCITS ETF is a UCITS-compliant, physically replicated ETF tracking the MSCI Emerging Markets Index using a sampling strategy. It may use derivatives for efficient portfolio management (EPM), such as managing inflows/outflows or hedging currency risk, but not as a core part of its investment strategy. Securities lending is permitted but is a secondary feature, managed within UCITS rules. The fund does not use leverage beyond UCITS limits, does not employ synthetic replication or swaps, and does not offer inverse exposure. The underlying index is transparent and well-documented. While the fund is exposed to emerging market risks (high volatility, regulatory, liquidity, and political risks), these are market risks inherent to the asset class, not structural complexity. The use of derivatives is limited to EPM and is disclosed, with counterparty risk mitigated by collateral policies. There is no evidence of embedded derivatives, complex payout structures, or features that would make the fundu2019s risk profile difficult for a retail investor with basic knowledge to understand. Under MiFID II, all UCITS are automatically non-complex unless they are structured UCITS (e.g., those with algorithm-based payoffs or similar complex features), which this fund is not[1]. The fundu2019s structure, risks, and objectives are straightforward and disclosed in the KIID, supporting a non-complex classification. The presence of derivatives for EPM and securities lending does not, in this case, override the UCITS presumption of non-complexity, as these features are ancillary, well-managed, and do not introduce structural opacity or advanced risks requiring specialist knowledge[1]. Therefore, the fund is classified as non-complex under MiFID II."
}