{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Currency hedging via derivatives, potential use of derivatives for efficient portfolio management, counterparty risk from OTC derivatives",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is authorized under the UCITS Directive and is therefore automatically classified as non-complex under MiFID II Article 25(4)(a)(iv), unless it is a structured UCITS or fails the Article 57 criteria[1]. The fund primarily uses physical replication to track the MSCI Japan 100% hedged to GBP Index, holding the underlying securities directly, which supports a non-complex classification. Derivatives are used for currency hedging (selling currency forwards) and, where necessary, for efficient portfolio management (EPM) to replicate the index when direct investment is not possible or practicable. The use of OTC derivatives introduces counterparty risk, but this is mitigated by the fund's collateral policy. There is no evidence of significant leverage, synthetic replication, embedded derivatives, or other complex features such as contingent convertible bonds, swaps, or complex indices. The fund's structure, risks, and objectives are transparent and typical for a passive equity UCITS ETF. Securities lending is permitted but is a secondary feature and managed within UCITS rules. The risk category is high due to equity market volatility, not structural complexity. The fund does not appear to be a structured UCITS as defined in Regulation (EU) No 583/2010, nor does it fail the Article 57 criteria for non-complex instruments. Therefore, despite the use of derivatives for hedging and EPM, the fund remains non-complex under MiFID II[1][2]."
}