{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Xtrackers MSCI Europe Health Care Screened UCITS ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF is a UCITS-compliant fund physically replicating the MSCI Europe Health Care Screened 20-35 Select 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 the KIID, PRIIPs KID, or factsheet. The fund may use derivatives only for risk management purposes, which does not trigger complexity under MiFID II. There is no leverage, inverse or amplified exposure. The underlying assets are large and mid-cap European healthcare equities, which are liquid and transparent. The risk profile is medium (4 out of 7), consistent with equity market risk, without elevated derivative or counterparty risk disclosures. No capital protection or structured features are present. Costs are straightforward with a simple ongoing charge of 0.17% and no performance fees or swap fees. Securities lending is minimal and revenue sharing is disclosed but does not increase costs. The index tracked is ESG screened with sector concentration but no complex structured indices or contingent bonds. No PRIIPs comprehension warnings or complexity flags are present. Overall, the fund exhibits a clear, linear relationship to the underlying index performance with minimal derivative use for hedging, physical replication, and no leverage or swaps, leading to a non-complex classification under MiFID II."
}