{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [],
        "classification": "non-complex",
        "supporting_data": "The asset is classified as a UCITS ETF, which are generally presumed non-complex under MiFID II due to their strict regulatory requirements. The provided ESMA guidelines (CESR/09-295, Section 3, paragraphs 69 and 80, and Annex I; ESMA35-36-1640, Section 2.1, footnote 12) explicitly state that UCITS are 'automatically non-complex by definition, for the purposes of the appropriateness requirements, regardless of the underlying instruments in which the UCITS invests'. The only exception to this for UCITS would be 'structured UCITS' which provide 'algorithm-based payoffs'.The ETF's investment policy explicitly states it uses 'Full Replication' and 'Optimised Replication' by holding the underlying 'Index equity securities'. This indicates a physical replication method, which is considered transparent and straightforward, further supporting a non-complex classification. There is no mention of synthetic replication, significant leverage, embedded derivatives, or complex debt instruments like Contingent Convertible Bonds. While the underlying index incorporates ESG criteria and Climate Transition Benchmark (CTB) targets, these define the selection methodology of listed equities and REITS, rather than introducing structural complexity to the ETF itself or making the payoff mechanism difficult to understand for a retail investor. The index methodology is publicly available, supporting transparency. The risk rating of 4/7 on the KID reflects market risk associated with equity investments, not structural complexity."
    }
}