{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Xtrackers MSCI Global Social Fairness Contributors UCITS ETF aims to track the MSCI ACWI IMI SDG Social Fairness Select Index by buying all or a substantial number of the underlying securities, indicating physical replication. The KIID and PRIIPs KID documents confirm the fund is passively managed with a straightforward index-tracking objective and no mention of synthetic replication, swap agreements, or funded/unfunded swaps. The fund may use derivatives only for risk management purposes, not as an inherent part of the investment strategy, which does not trigger complexity under MiFID II. There is no leverage, inverse exposure, or capital protection mechanism. The underlying assets are equities globally diversified across large, mid, and small caps with ESG and SDG thematic screens, but no complex structured products or contingent convertible bonds are held. The risk profile is medium-high (category 6 in KIID, category 4 in PRIIPs), reflecting market volatility and sector/geographic concentration risks, but not complexity from derivatives or leverage. Costs are straightforward with a single ongoing charge of 0.35% and no performance fees or swap fees. The factsheet explicitly states direct physical replication and no use of swaps. No complexity flags such as counterparty risk, capital protection, or complex fee structures are present. The index tracked is transparent and liquid, with 231 constituents, and no complex derivatives embedded in the index methodology. Therefore, the fund is classified as non-complex under MiFID II despite a medium risk rating due to market volatility and ESG thematic focus."
}