{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The Xtrackers EMU Net Zero Pathway Paris Aligned UCITS ETF is a UCITS-compliant ETF that physically replicates the Solactive ISS ESG Developed Markets Eurozone Net Zero Pathway 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 any of the KIID, PRIIPs KID, or factsheet documents. The fund may use derivatives only as risk management tools, which does not trigger complexity under MiFID II. There is no leverage or inverse exposure indicated. The underlying assets are large and mid-cap Eurozone equities, which are liquid and transparent. The risk profile is medium-high (risk category 5 out of 7), reflecting market risk rather than structural complexity. No capital protection or structured features are present. Costs are straightforward with a simple ongoing charge of 0.15% and no performance fees or swap fees. The index tracked is ESG-screened and tilted but does not involve complex derivatives or contingent bonds. No counterparty risk or collateral management risks are disclosed. There is no PRIIPs comprehension warning or complexity flag. Therefore, the ETF is classified as non-complex under MiFID II criteria."
}