{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "None",
    "classification": "non-complex",
    "supporting_data": "The Xtrackers MSCI Europe Value UCITS ETF is a UCITS-compliant, physically replicated ETF tracking a transparent, rules-based equity index (MSCI Europe Enhanced Value TRN). It does not use derivatives as a core part of its investment strategyu2014derivative use, if any, is limited to efficient portfolio management (EPM) with minimal impact on risk-return, as disclosed in the KID. There is no evidence of synthetic replication, embedded derivatives, leverage beyond UCITS limits, or other complex features. The ETFu2019s structure, risks, and investment objective are straightforward and disclosed in a manner accessible to retail investors. Under MiFID II, all UCITS are automatically non-complex unless they are structured UCITS or fail the Article 57 criteriau2014neither applies here[1][2]. The ETFu2019s risk profile (category 6) reflects market volatility, not structural complexity. Securities lending is present but is a secondary, well-managed feature within UCITS rules and does not introduce material complexity. The index is transparent and the ETFu2019s holdings are fully disclosed. No comprehension alert is required or indicated."
}