{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Xtrackers MSCI Europe Consumer Discretionary Screened UCITS ETF",
    "investment_objective": "To track the performance, before fees and expenses, of the MSCI Europe Consumer Discretionary Screened 20-35 Select Index",
    "primary_asset_class": "Equity",
    "geographic_focus": "Europe (15 developed markets)",
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF physically replicates the MSCI Europe Consumer Discretionary Screened 20-35 Select 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 total return swaps in any of the documents. The fund may use derivatives only for risk management purposes, which does not trigger complexity under MiFID II. There is no leverage, inverse exposure, or capital protection features. The underlying assets are large and mid-cap equities in developed European markets, screened for ESG criteria, with no complex structured products or contingent bonds. The risk profile is medium-high (5/7) due to sector concentration and market volatility, but this does not imply complexity under MiFID II. Costs are straightforward with a single ongoing charge of 0.17% and no performance fees or swap fees. No complexity warnings or comprehension warnings are present in the PRIIPs KID. Therefore, the ETF is classified as non-complex under MiFID II."
}