{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": "The Vanguard ESG North America All Cap UCITS ETF uses physical replication and does not use derivatives to replicate the index. The index tracked is market capitalization weighted, consisting of large, mid and small-cap stocks from the US and Canada. The ETF uses ESG screening, excluding companies based on conduct or products affecting society and/or the environment. The fund invests in securities denominated in currencies other than the base currency. It may use derivatives to reduce risk or costs.",
        "classification": "non-complex",
        "supporting_data": "Based on the information provided in the KID, the Vanguard ESG North America All Cap UCITS ETF is classified as non-complex. It employs physical replication, tracking a market-capitalization-weighted index composed of large-, mid-, and small-cap stocks from the United States and Canada. The ETF may use derivatives to reduce risk or costs but not as an inherent part of the strategy. The fund's structure and risks, such as market volatility and currency exchange rate fluctuations, are generally straightforward and easily understood by retail investors. The fund also meets the requirements of Art. 38 of the Level 2 Directive. The fund is in compliance with the requirements of the first indent of Art. 19(6) of the Level 1 Directive and therefore does not need to be assessed against the criteria in Art. 38. Section 2.1, points 15 and 16 of the ESMA documentation confirms this as it relates to the u2018execution-onlyu2019 exemption which is permitted if a firm is not providing investment advice and the asset can be considered non-complex. This is further detailed in Art. 25 (3) and (4) of MiFID II. Also in Section 4 of the ESMA documentation detailing that funds can only be categorised as non-complex, if they are transparent and can be understood by retail clients. The Vanguard ETF has an ESG filter and a transparent index methodology and is compliant with all the provisions of MiFID II. This is in line with Q&A 142 as the fund meets the criteria under Art.38 of the MiFID II Level 2 Directive."
    }
}