{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": "Complex Index",
        "classification": "complex",
        "supporting_data": "The asset is a UCITS ETF, which establishes a presumption of being non-complex. It employs a physical replication method by 'buying all or a substantial number of the securities in the index', which is a straightforward and non-complex approach. The KIID states that derivatives may be used for efficient portfolio management ('to manage risk, reduce costs and improve results'), not as a core part of the investment strategy to achieve its objective, which on its own would support a non-complex classification.However, the ETF's classification is determined to be 'complex' due to the nature of the index it tracks: the 'MSCI ACWI IMI SDG 12 Responsible Consumption and Production Select Index'. This is not a standard, broad-market index. Its construction involves a multi-layered and opaque process that is difficult for a typical retail investor to understand. The methodology includes: 1. A base universe (MSCI ACWI IMI).2. Multiple screening layers (ESG standards, SDG impact criteria, SDG thematic criteria).3. A complex weighting methodology based on the product of market capitalisation and either revenue exposure or a 'relevance score', which is then scaled.This bespoke index construction introduces a significant layer of complexity. An average retail investor cannot easily understand the precise reasons for a security's inclusion, exclusion, or its specific weighting within the fund. This lack of transparency and the advanced knowledge required to comprehend the index's mechanics and risk drivers lead to the conclusion that the ETF is difficult to understand, thereby overriding the initial non-complex presumption. Under MiFID II, an instrument is complex if its structure or risks are not easily understood, and the complexity of this index is the determining factor."
    }
}