{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Xtrackers S&P 500 Equal Weight Scored & Screened UCITS ETF is a UCITS-compliant ETF that physically replicates the S&P 500 Equal Weight ESG Index by direct purchase of underlying securities, as confirmed by the factsheet stating 'Direct Replication (physically)'. The fund is passively managed with a straightforward index-tracking objective focused on large-cap US equities with ESG criteria. Although the KIID and PRIIPs documents mention that the fund 'may employ techniques and instruments including derivatives to manage risk, reduce costs and improve results,' there is no indication that derivatives or swaps are used as an inherent part of the investment strategy. The risk disclosures note derivatives risk only in the context of risk management, not as a core strategy element, so derivatives are considered non-inherent and thus 'derivatives' is false. There is no leverage, inverse exposure, or capital protection features. The underlying assets are liquid, transparent large-cap equities without complex structured products. The risk profile is medium-high (risk level 5 out of 7), reflecting market volatility and concentration risk, but not complexity from product structure. Costs are simple with a low ongoing charge (0.17%) and no performance fees or swap fees. No counterparty risk or swap counterparty exposure is disclosed. The index tracked is rules-based but not complex or contingent. No references to synthetic replication, funded or unfunded swaps, or complex derivatives are found. The PRIIPs KID does not include any comprehension warnings or complexity flags beyond normal market risks. Therefore, under MiFID II criteria, this ETF is classified as non-complex."
}