{
    "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 Emerging Markets UCITS ETF is a UCITS-compliant ETF that uses a sampling strategy to replicate the MSCI Emerging Markets Index. It primarily invests in a representative sample of the index's constituent stocks using portfolio optimization techniques. The fund may use derivatives only for efficient portfolio management purposes, such as when direct replication is not possible or practicable, and these uses are limited and mitigated by collateral policies. The ETF employs physical replication (holding underlying securities or close substitutes) rather than synthetic replication. There is no indication of embedded derivatives, significant leverage, or complex structured products such as CLOs. Securities lending is possible but managed within UCITS rules. The fund tracks a transparent, well-known equity index, and the risks (market volatility, tracking error, currency fluctuations) are straightforward and understandable by retail investors with basic knowledge. The risk category is high due to emerging market volatility but this reflects market risk, not structural complexity. According to MiFID II Article 25(4)(a)(iv) and Article 57 criteria, UCITS ETFs that do not embed derivatives as a core strategy and use physical replication are automatically non-complex. The limited use of derivatives for efficient portfolio management does not trigger complexity classification. Therefore, this ETF is classified as non-complex under MiFID II. This aligns with ESMA and CESR guidance that physical replication UCITS ETFs without embedded derivatives or complex features are non-complex. No comprehension alert is required in the KID for this ETF."
}