{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Xtrackers MSCI EMU Climate Transition UCITS ETF is a UCITS-compliant ETF that physically replicates the MSCI EMU Select Sustainability Screened CTB 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, total return swaps, or derivative instruments used as part of the investment strategy, only limited use of derivatives for risk management purposes, which does not trigger complexity under MiFID II. The fund does not employ leverage, inverse or amplified exposure. The underlying assets are large and mid-cap equities in developed European markets, which are liquid and transparent. There are no capital protection or structured features. The risk profile is medium (4 out of 7), consistent with equity market risk, without additional complexity flags such as significant counterparty risk or complex derivative usage. Costs are straightforward with a low ongoing charge (0.12%) and no performance fees or swap fees. The PRIIPs KID does not include any comprehension warnings or complexity flags. The index tracked is ESG-screened but does not involve complex structured products or contingent bonds. Therefore, the ETF is classified as non-complex under MiFID II criteria."
}