{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Xtrackers S&P 500 Scored & Screened UCITS ETF is a UCITS-compliant ETF that physically replicates the S&P 500 ESG TRN 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 exposure, or capital protection features. The underlying assets are large-cap US equities screened for ESG criteria, which are liquid and transparent securities. The risk profile is moderate (category 4 in KIID, 5/7 in PRIIPs KID), consistent with equity market risk but not indicative of complexity. Costs are straightforward with a low ongoing charge (0.08%) and no performance fees or swap fees. No complexity flags such as contingent bonds, structured products, or significant counterparty risk are present. The index tracked is rules-based and transparent, with no complex or contingent return formulas. Therefore, the ETF is classified as non-complex under MiFID II."
}