{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Xtrackers MSCI USA ESG UCITS ETF",
    "investment_objective": "To track the performance, before fees and expenses, of the MSCI USA Low Carbon SRI Selection Index",
    "primary_asset_class": "Equity",
    "geographic_focus": "USA",
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF physically replicates the MSCI USA Low Carbon SRI Selection Index by buying all or a substantial number of the underlying securities, as confirmed by the factsheet stating 'Direct Replication (physically)'. There is no mention of synthetic replication, swap agreements, or derivative instruments used as part of the investment strategy, only derivatives potentially used for risk management, which does not trigger complexity. The fund is UCITS compliant and has a straightforward index-tracking objective focused on large and mid-cap US equities with ESG and low carbon criteria. The risk profile is medium-high (5/7), reflecting equity market risk rather than structural complexity. No leverage, inverse exposure, capital protection, or complex structured products are involved. Costs are simple with a TER of 0.15% and no performance fees. The PRIIPs KID does not include any comprehension warnings or complexity flags. The index tracked is rules-based with ESG and carbon emission filters but does not involve complex derivatives or contingent bonds. Therefore, under MiFID II criteria, this ETF is classified as non-complex."
}