{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The UBS (Lux) Fund Solutions - MSCI EMU Socially Responsible UCITS ETF is a UCITS-compliant ETF that tracks the MSCI EMU SRI Low Carbon Select 5% Issuer Capped Index. The fund primarily invests directly in the underlying equities of the index, using physical replication or representative sampling. The KIID and PRIIPs KID documents mention that derivatives may be used only where it is not possible or practicable to replicate the index directly or to generate efficiencies, but this is limited and for risk management or operational purposes rather than as an inherent part of the investment strategy. There is no mention of synthetic replication, swap agreements, total return swaps, or funded/unfunded swap structures. No leverage, inverse, or amplified return features are present. The risk profile is medium (4 out of 7 in PRIIPs KID, 6 in KIID but driven by equity volatility rather than complexity). The fund does not engage in securities lending, has a simple fee structure (ongoing charges around 0.20%), and no performance fees. The underlying assets are equities of developed market companies within the European Economic and Monetary Union, with ESG and social responsibility screens applied, but no complex structured products or contingent convertible bonds are held. The PRIIPs KID explicitly states the product is 'not simple and may be difficult to understand' due to ESG and index construction complexity, but this does not translate into synthetic replication or derivative-based complexity under MiFID II. No capital protection or structured features are present. Therefore, the fund does not meet the MiFID II criteria for a complex financial instrument."
}