{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Xtrackers MSCI USA Climate Transition UCITS ETF",
    "replication_method": "physical",
    "leverage": false,
    "inverse": false,
    "derivatives": false,
    "swaps": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF aims to replicate the MSCI USA Select Sustainability Screened CTB Index by buying all or a substantial number of the underlying securities, indicating physical replication. The factsheet explicitly states 'Direct Replication (physically)'. There is no mention of synthetic replication, swap agreements, total return swaps, or derivative instruments used as part of the investment strategy, only that derivatives may be used 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 US equities, which are liquid and transparent. The risk profile is high (category 6 in KIID, 5 in PRIIPs) due to market volatility and concentration risk, but this is typical for equity ETFs and does not imply complexity. No capital protection or structured features are present. Costs are straightforward with a low ongoing charge of 0.09% and no performance fees or swap fees. The PRIIPs KID does not include any comprehension warnings or complexity flags. The index tracked is ESG- and climate-transition focused but does not involve complex structured products or contingent bonds. Overall, the ETF is a straightforward physical equity index tracker with minimal derivative use for risk management, no leverage, and no synthetic replication, thus classified as non-complex under MiFID II."
}