{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivative use for efficient portfolio management, not central to strategy",
    "classification": "non-complex",
    "supporting_data": "The UBS MSCI Japan Socially Responsible UCITS ETF is a UCITS-compliant, physically replicated ETF tracking a transparent equity index. While it may use derivatives for efficient portfolio management (EPM)u2014such as managing inflows/outflows, hedging currency risk, or reducing transaction costsu2014the KID states that such use is limited and not central to the investment strategy. There is no evidence of synthetic replication, embedded derivatives, significant leverage, or complex underlying assets. The ETF does not engage in securities lending. The risk profile is high due to equity market volatility, but this reflects market risk, not structural complexity. Under MiFID II, all UCITS are automatically non-complex unless they are structured UCITS or use derivatives as a core part of the strategy, which is not the case here[1][2]. The derivative use described is consistent with EPM, which does not trigger a complex classification under MiFID II Article 57, provided the impact on the risk-return profile is minimal and the structure remains transparent and understandable for retail investors[1][2]. The ETFu2019s structure, objectives, and risks are clearly disclosed, supporting a non-complex classification."
}