{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Xtrackers MSCI Japan Climate Transition UCITS ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF is a UCITS-compliant fund physically replicating the MSCI Japan Select Sustainability Screened CTB Index by direct purchase of underlying securities, as confirmed by the factsheet stating 'Direct Replication (physically)'. There is no mention of synthetic replication, swap agreements, or total return swaps in the KIID, PRIIPs KID, or factsheet. The fund may use derivatives only for risk management purposes, which does not trigger complexity under MiFID II. There is no leverage, inverse or amplified exposure language. The underlying assets are large and mid-cap Japanese equities, which are liquid and transparent. The risk profile is medium (4 out of 7), consistent with equity market risk, without elevated derivative or counterparty risk disclosures. No capital protection or structured features are present. Costs are straightforward with a simple ongoing charge of 0.15% and no performance fees or swap fees. The PRIIPs KID does not include any comprehension warnings or complexity flags. The index tracked is ESG-screened but does not involve complex structured products or contingent bonds. Therefore, the fund does not meet any MiFID II complexity criteria related to synthetic replication, leverage, complex underlying assets, or capital protection mechanisms."
}