{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "physical",
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "leverage": false,
        "complex_factors": [
            "ESG criteria may introduce complexity in understanding the index methodology.",
            "The fund's objective is to reflect the performance of an index, which involves understanding index construction and potential tracking differences."
        ],
        "classification": "non-complex",
        "supporting_data": "The fund is a UCITS ETF, which starts with a presumption of being non-complex. It aims to track the MSCI USA Select Sustainability Screened CTB Index, which is based on ESG criteria and climate transition benchmarks. While the ESG screening and index methodology add layers of detail, the core investment strategy is to replicate an index using physical replication ('buying all or a substantial number of the securities in the index'). The document states that the fund 'may employ techniques and instruments in order to manage risk, reduce costs and improve results,' but specifically mentions 'the use of financial contracts (derivatives)' as a possibility and not a certainty or core strategy. The risk indicator is Category 6, signifying high potential for losses and gains due to market volatility, which is a characteristic of many ETFs and does not inherently make the product complex from a structural perspective. There is no mention of embedded derivatives, leverage beyond standard UCITS limits, or complex underlying assets that would typically lead to a complex classification. The complexity introduced by ESG criteria is generally considered manageable for an informed retail investor in the context of an ETF. The primary method of replication is physical, which is straightforward. The risks highlighted are standard for equity investments and tracking error, not structural complexity. Therefore, based on the provided information and the MiFID II framework, the ETF is classified as non-complex."
    }
}