{
    "type": "ETF",
    "ucits": true,
    "fund_name": "iShares Growth Portfolio UCITS ETF EUR (Acc)",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": "Active management with multi-asset exposure; indirect investment via other UCITS ETFs; use of derivatives only for risk reduction and cost management; no leverage or synthetic replication; ESG screening reducing investment universe",
    "classification": "non-complex",
    "supporting_data": "The Fund is a UCITS ETF actively managed without a benchmark, investing predominantly in other UCITS mutual funds and ETFs, with at least 80% of assets in ESG-compliant funds. The replication is physical via underlying funds, not synthetic. The Fund may use derivatives only for risk reduction, cost management, and generating additional income, not as an inherent part of the investment strategy, so derivative use is incidental, not structural. There is no mention of swap agreements, total return swaps, or counterparty exposure related to synthetic replication. No leverage or inverse exposure is present. The risk profile is moderate (risk level 4-5 in PRIIPs, 5 in KIID), consistent with multi-asset equity and fixed income exposure. The Fund engages in securities lending with revenue sharing but no complex fee structures or performance fees. The underlying assets are diversified, liquid UCITS ETFs and funds, with no complex structured products or contingent bonds. No capital protection or structured features are present. The PRIIPs KID confirms medium risk (4/7), no capital guarantee, and no leverage. The monthly factsheet confirms no synthetic replication or swap usage, and the portfolio is composed mainly of other ETFs with ESG focus. Overall, the Fund\u2019s structure and disclosures indicate a straightforward, physically replicated, multi-asset UCITS ETF with incidental derivative use for risk management, thus non-complex under MiFID II criteria."
}