{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "ESG screening criteria",
            "Complex index methodology"
        ],
        "classification": "non-complex",
        "supporting_data": "The Xtrackers MSCI Global SDG 9 Industry, Innovation & Infrastructure UCITS ETF aims to track the performance of the MSCI ACWI IMI SDG 9 Industry, Innovation and Infrastructure Select Index. The index is based on the MSCI ACWI IMI Index and includes companies that contribute positively to UN SDG 9, subject to ESG screening. The ETF employs physical replication by buying all or a substantial number of the securities in the index. While it states it 'may employ techniques and instruments in order to manage risk, reduce costs and improve results' and 'may include the use of financial contracts (derivatives)', the primary replication method is physical. The KIID rates the fund in category 6 of the risk/reward profile due to potential strong fluctuations in share price. The document highlights market risk, exceptional circumstances, conflicts of interest, no guarantee, shares risk, emerging markets risk, and sustainability risk. Crucially, the text states: 'The fund is passively managed.' and 'To achieve the aim, the fund will attempt to replicate the index, before fees and expenses, by buying all or a substantial number of the securities in the index.' The ESG screening and SDG impact selection criteria, while adding complexity to the index construction, do not inherently make the ETF itself complex under MiFID II rules concerning structure and understanding for a retail investor. The core mechanism of tracking a physical index is considered non-complex. There is no mention of embedded derivatives, leverage beyond what is standard for index tracking, or other features that would typically classify an ETF as complex according to MiFID II and ESMA guidelines. The reference to derivatives is in the context of potential use for risk management or cost reduction, not as the core replication strategy, and even then, the general presumption for UCITS ETFs is non-complex unless these derivatives are integral to the strategy and introduce undue complexity or risk. The complexity of the index methodology itself, due to ESG and SDG criteria, is not a direct determinant of the ETF's structural complexity under MiFID II, but rather the underlying strategy and its transparency. Given the physical replication and clear objective to track an index, it remains non-complex. The ESMA guidelines in CESR/09-295 and the MiFID II Supervisory Briefing on Appropriateness and Execution-Only consistently lean towards physical replication of transparent indices as non-complex. The ESG/SDG criteria are part of the index's selection process, not a derivative overlay on the ETF's structure itself. Therefore, based on the provided KIID information, the ETF's structure and investment policy align with a non-complex classification."
    }
}