{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Invesco S&P 500 CTB Net Zero Pathway ESG UCITS ETF",
    "investment_objective": "Provide exposure to large capitalisation listed US companies with reduced exposure to transition risks to a lower carbon economy by tracking the S&P 500 Climate Transition Base Pathway-Aligned ESG Index.",
    "primary_asset_class": "Equity",
    "geographic_focus": "United States",
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Fund uses physical replication by holding all or substantially all securities in the underlying S&P 500 Climate Transition Base Pathway-Aligned ESG Index in similar proportions. There is no mention of synthetic replication, swap agreements, total return swaps, or derivative instruments as part of the investment strategy. The PRIIPs KID confirms that derivatives may be used only for risk management or cost reduction purposes, not as an inherent element of the strategy, so derivatives exposure is minimal and not complexity-driving. There is no leverage, inverse or amplified exposure. The underlying assets are large-cap US equities, liquid and transparent securities, with no complex structured products or contingent bonds. The risk rating is 5 out of 7, indicating medium-high risk typical for equity ETFs but not necessarily complexity. The ongoing charges are low (0.09%-0.10%), with no performance fees or swap fees. Securities lending is used but is a common practice and does not add complexity. The index tracked is a climate-transition ESG variant of the S&P 500, constructed by exclusion and optimisation but remains a straightforward equity index without embedded derivatives or complex features. No capital protection or structured features are present. The monthly factsheet confirms physical replication and no synthetic or swap usage. Overall, the ETF aligns with MiFID II criteria for non-complex instruments due to its physical replication, lack of leverage, absence of synthetic or derivative-based replication, and straightforward underlying assets.",
    "risk_level_assessment": "The Fund's risk category is 6 out of 7, reflecting equity market risk and ESG-related concentration risks, but this risk level does not imply complexity under MiFID II. The risk disclosures do not indicate significant counterparty risk, derivative risk, or liquidity risk beyond normal market conditions."
}