{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The Xtrackers II ESG Global Aggregate Bond UCITS ETF is a UCITS-compliant ETF that physically replicates the Bloomberg MSCI Global Aggregate Sustainable and SRI Currency Neutral Index by directly purchasing a portfolio of investment-grade fixed-rate bonds. The factsheet explicitly states 'Direct Replication (physically)' and 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 for risk management purposes, which does not trigger complexity under MiFID II. There is no leverage, inverse or amplified exposure language present. The underlying assets are investment-grade bonds, which are liquid and transparent, with no complex structured products or contingent convertible bonds involved. The risk profile is moderate (risk category 4 in KIID, 3 in PRIIPs KID), consistent with a straightforward bond ETF. Costs are simple with a low ongoing charge of 0.10% and no performance fees or swap fees. No capital protection or structured features are present. There are no significant counterparty risk disclosures beyond normal custodial risk. The index tracked is broad-based and transparent, with ESG exclusions but no complex derivatives embedded. No PRIIPs comprehension warnings or retail investor suitability warnings indicating complexity are present. Therefore, the ETF is classified as non-complex under MiFID II criteria."
}