{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The UBS (Lux) Fund Solutions - MSCI Japan UCITS ETF is a UCITS-compliant ETF that primarily uses physical replication by investing directly in the underlying securities of the MSCI Japan Index or through derivatives only when direct replication is not practicable, mainly for efficient portfolio management (EPM). The derivatives use is limited, with counterparty risk mitigated by a collateral policy. There is no indication of embedded derivatives, leverage beyond UCITS limits, or complex structured products such as CLOs. Securities lending is possible but managed within UCITS rules and does not dominate the risk profile. The ETF tracks a transparent equity index with a straightforward risk profile reflecting market volatility, not structural complexity. The fund is classified as risk category 6 due to market volatility, which does not imply complexity under MiFID II. According to MiFID II Article 25(4)(a)(iv) and Article 57 of the Commission Delegated Regulation, UCITS ETFs that use physical replication and limited derivatives for EPM with minimal impact on risk-return are non-complex. The ETF does not embed derivatives integral to its strategy, nor does it use synthetic replication or leverage. Therefore, it meets the criteria for non-complex classification under MiFID II. This assessment aligns with ESMA guidance that physical replication UCITS ETFs with limited derivative use for EPM are non-complex, while synthetic or structured UCITS ETFs with embedded derivatives or complex features would be complex. No evidence suggests the ETF falls under complex categories such as structured UCITS or synthetic ETFs. Hence, the ETF is non-complex under MiFID II."
}