{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "physical",
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "leverage": false,
        "complex_factors": [],
        "classification": "non-complex",
        "supporting_data": "The ETF aims to reflect the performance of the Solactive ISS ESG United States Net Zero Pathway Index, which is described as a benchmark for large and medium capitalization companies in the USA aligned with EU Paris-aligned Benchmark (EU PAB) standards and net zero frameworks. The fund uses physical replication, buying all or a substantial number of the securities in the index. While it mentions the possibility of using financial contracts (derivatives) for risk management, cost reduction, or improving results, this is presented as a secondary possibility and not integral to the strategy. The ETF's risk profile is classified as category 6 out of 7, indicating potentially high fluctuations and likelihood of both gains and losses, but this is attributed to market movements, not structural complexity. The index methodology is based on ESG data and screening, which might be complex in itself, but the ETF's structure is straightforward. The document clearly states that UCITS are presumed non-complex by default under MiFID II (Article 19(6) of Level 1 Directive, confirmed in Annex I of CESR/09-295). There are no indications of embedded derivatives, leverage, or other complex features that would typically lead to a complex classification. The primary replication method is physical, and the description of the index, while ESG-focused, does not suggest inherent complexity in its payoff structure or derivative use. Therefore, based on the provided information and the MiFID II framework for UCITS ETFs, this ETF is classified as non-complex."
    }
}