{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The Xtrackers USA Biodiversity Focus SRI UCITS ETF is a UCITS-compliant ETF that physically replicates the ISS STOXX\u00ae US Biodiversity Focus SRI 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 documents. The fund may use derivatives only for risk management purposes, which does not trigger complexity under MiFID II. There is no leverage or inverse exposure; the fund is passively managed with a straightforward index-tracking objective. The underlying assets are large and medium capitalization equities screened for ESG and biodiversity criteria, with no complex structured products or contingent bonds involved. The risk profile is medium-high (category 5 out of 7), reflecting market risk rather than structural complexity. Costs are simple, with a single ongoing charge of 0.30% and no performance fees or swap fees. No capital protection or structured features are present. The PRIIPs KID does not include any comprehension warnings or complexity flags. Therefore, the fund does not meet the MiFID II criteria for classification as a complex financial instrument."
}