{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Xtrackers World Small Cap Green Tech Innovators UCITS ETF",
    "investment_objective": "Achieve positive mid- to long-term investment performance through investments in small capitalisation listed global equities facilitating green technologies development and application",
    "primary_asset_class": "Equity",
    "geographic_focus": "Global",
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The ETF is a UCITS-compliant, actively managed equity fund investing directly in small and mid-cap global equities focused on green technologies. The factsheet explicitly states the portfolio methodology is 'Direct Replication (physically)', with no mention of synthetic replication or swap usage. The KIID confirms derivatives may be used only for risk management, cost reduction, or efficiency purposes, not as an inherent part of the investment strategy, so derivatives are marked false. There is no leverage, inverse or amplified exposure language. The risk rating is 6, reflecting volatility of small caps and ESG risks, but no complexity flags such as capital protection, structured products, or contingent bonds are present. Charges are straightforward with no performance fees or swap fees. No counterparty risk or collateral management risks are disclosed. The fund invests in liquid, transparent equities with no complex underlying assets. The absence of synthetic replication, leverage, complex underlying assets, or capital protection features leads to a non-complex classification under MiFID II. Although the risk level is relatively high (6), this is due to equity volatility and ESG factors, not structural complexity. No PRIIPs comprehension warnings or complex index references were found. Therefore, the fund is classified as non-complex."
}