{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "None",
    "classification": "non-complex",
    "supporting_data": "The ETF is a UCITS-compliant, passively managed fund tracking a transparent, well-documented equity index (Solactive GBS Developed Markets Europe Large & Mid Cap EUR Index) using direct physical replication. Derivatives are used only for efficient portfolio management (EPM) to handle inflows/outflows or to gain better exposure to index constituents, not as a core strategy. Securities lending is permitted but is a secondary, well-managed feature within UCITS rules. The fund does not use significant leverage, synthetic replication, or embedded derivatives. The structure, risks (primarily market risk), and investment objective are straightforward and easily understood by retail investors with basic knowledge. The ETF meets all criteria for non-complex classification under MiFID II Article 57 and the UCITS presumption, with no features that would trigger a complex classification under regulatory guidelines[1][2]."
}