{
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": "Derivative use for efficient portfolio management and currency hedging, Counterparty risk from OTC derivatives, Securities lending",
    "classification": "non-complex",
    "supporting_data": "The ETF is a UCITS-compliant, physically replicated fund tracking the MSCI Switzerland 20/35 100% hedged to USD Index. It primarily holds the underlying securities of the index, supporting a non-complex classification under MiFID II Article 25(4)(a)(iv) and the general UCITS presumption[1]. Derivatives are used only for efficient portfolio management (EPM)u2014specifically, to manage inflows/outflows, hedge currency risk (via currency forwards), and potentially to generate efficiencies where direct replication is not practicable. This derivative use is limited, well-disclosed, and does not form the core of the investment strategy. The ETF may also engage in securities lending, which is a common, secondary feature in UCITS ETFs and, if well-managed within UCITS rules, does not automatically trigger complexity. The fundu2019s structure, risks (primarily market volatility and tracking error), and investment objective are transparent and easily understood by retail investors with basic knowledge. There is no significant leverage, no embedded derivatives, and no indication of a complex or opaque index. The presence of counterparty risk from OTC derivatives is acknowledged but mitigated by the fundu2019s collateral policy, and the overall risk profile remains consistent with a non-complex, equity-focused UCITS ETF. Therefore, despite limited derivative use for EPM and hedging, the ETF does not incorporate features that make it difficult for the average retail investor to understand the risks involved, and it remains non-complex under MiFID II[1]."
}