{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "physical",
        "derivatives": false,
        "swaps": false,
        "leverage": false,
        "inverse": false,
        "complex_factors": [
            "ESG exclusionary criteria in index methodology"
        ],
        "classification": "non-complex",
        "supporting_data": "The iShares Global Clean Energy UCITS ETF aims to achieve a return that reflects the S&P Global Clean Energy Index. It achieves this by investing in equity securities that make up the index, indicating a physical replication method. The fund does not explicitly mention the use of derivatives for its primary investment objective, and securities lending is described as a secondary activity to offset costs, with revenue sharing not increasing fund costs. The index methodology includes ESG exclusionary criteria, which adds a layer of sophistication to the index itself, but this does not automatically render the ETF complex under MiFID II as the underlying investment is in publicly traded equities. The fund's structure is a UCITS ETF, which is generally presumed non-complex. The risk profile is rated seven, but this is attributed to the nature of the investments (clean energy industry risks) rather than complex structural elements. The Key Investor Information Document (KIID) does not indicate any embedded derivatives, significant leverage, or other features that would typically lead to a complex classification. The focus is on holding underlying equities of companies in the clean energy sector, which are generally understood by retail investors, even if the sector itself has specific risks. The mention of potential currency differences affecting share performance is a standard consideration for global ETFs and does not indicate complexity. The use of financial derivative instruments (FDIs) is mentioned as a possibility for achieving the investment objective, but the primary aim is to invest in equity securities of the index. Without specific details on how FDIs are used, and given the primary strategy is physical replication of equities, it leans towards non-complex. The key nuance here is that while the index has ESG criteria, the investment itself is in listed equities, which are generally considered non-complex under MiFID II. The presence of ESG exclusionary criteria in the index methodology is a factor that might make the index itself more complex to understand for some retail investors, but the ETF's direct holding of equities does not inherently introduce the structural complexity that would typically classify an ETF as complex (e.g., synthetic replication, embedded derivatives, leverage).",
        "classification_reasoning": "The iShares Global Clean Energy UCITS ETF aims to replicate the S&P Global Clean Energy Index through physical investment in equity securities. As a UCITS ETF, it benefits from a general presumption of being non-complex. The key investment strategy involves holding underlying equities, which is a straightforward approach. While the index methodology includes ESG exclusionary criteria, this complexity relates to the index's construction and not to a complex financial structure within the ETF itself. The document does not indicate the use of derivatives for replication, significant leverage, or any other structural complexity that would typically lead to a complex classification under MiFID II. The mention of potential FDI use is general and does not override the primary physical replication strategy. Therefore, the ETF is classified as non-complex."
    }
}