{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "ESG integration involves active stock selection that deviates from the benchmark. ESG scores and exclusions are used for security selection, but the ETF's core objective is to track a US equity index. This approach introduces a degree of portfolio construction deviation from simple index tracking",
            "The ETF applies a binding and significant ESG integration approach to select securities from the Investment Universe with a view to improving the Fundu2019s ESG profile compared to that of the Index."
        ],
        "classification": "non-complex",
        "supporting_data": "The ETF aims to provide exposure to the US equity market while integrating ESG criteria. The investment policy is to track the S&P 500 Net Total Return Index (SPTR500N Index) using an active strategy by selecting securities from the Investment Universe to enhance its ESG profile compared to the Index. The Fund deviates from the index in terms of the weightings of the portfolio and includes exclusions, a lower carbon footprint and board gender diversity. The fund also uses tracking-error and sector controls to limit performance deviation from the Index. There is no mention of derivatives, swaps, leverage or complex indices. There is no indication of embedded derivatives. The ETF uses a physical replication method and the fund's structure and risks are likely to be understood by retail investors with basic knowledge. Based on the information provided, the ETF is considered a non-complex financial instrument under MiFID II. "
    }
}