{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivative use for efficient portfolio management, potential counterparty risk, but not central to strategy",
    "classification": "non-complex",
    "supporting_data": "The UBS MSCI Switzerland 20/35 UCITS ETF is a UCITS-compliant, physically replicated ETF tracking a transparent equity index. It may use derivatives for efficient portfolio management (EPM), such as managing inflows/outflows or hedging currency risk, but derivatives are not central to its investment objective. The KID states that derivatives may be used 'where it may not be possible or practicable to replicate the index through direct investments or in order to generate efficiencies in gaining exposure to the index,' and that OTC derivatives introduce counterparty risk, which is mitigated by the fund's collateral policy. There is no evidence of synthetic replication, leverage beyond UCITS limits, embedded derivatives, or other complex features. The fund's structure, risks, and objective are straightforward and disclosed in plain language. Under MiFID II, UCITS ETFs are generally presumed non-complex unless they are 'structured UCITS' or use derivatives as a core part of the strategy, which is not the case here. The use of derivatives for EPM with robust risk mitigation does not automatically trigger a complex classification under ESMA and FCA guidance, provided the impact on the risk-return profile is minimal and well-disclosed[1]. Therefore, this ETF remains non-complex for MiFID II purposes."
}