{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "leverage": false,
        "derivates": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "complex_factors": "ESG index selection may incorporate complex methodologies",
        "classification": "non-complex",
        "supporting_data": "The ETF is UCITS compliant and seeks to track the MSCI ACWI SRI Low Carbon Select 5% Issuer Capped Index (Net Return).  It utilizes physical replication.  Derivatives may be used for reducing risk, reducing costs or generating additional capital or income, suggesting derivatives are not an integral part of the investment strategy. The index uses ESG methodology which may be difficult for investors to fully understand.",
        "complex": false,
        "non-complex": true,
        "esma_guidelines": {
            "appropriateness_assessment_required": "Relevant. The document outlines the importance of determining situations where the appropriateness assessment is required. Specifically, Article 25(4) of MiFID II allows for an exemption from the appropriateness test for 'execution-only' business under certain conditions, such as distinguishing between complex and non-complex instruments (ESMA35 -36 -1640 - Section 2.1)",
            "obtaining_information_from_clients": "Relevant. Article 25(3) of MiFID II and Article 56 of the MiFID II Delegated Regulation require firms to determine whether a client has the necessary experience and knowledge to understand the risks involved in relation to the investment product or service offered or demanded. Section 2.2 covers the type of information that should be requested from clients (ESMA35 -36 -1640 - Section 2.2)",
            "assessment_of_appropriateness": "Relevant. It is necessary to confirm the product is 'appropriate'. In accordance with Article 56 (1) of the MiFID II Delegated Regulation , firms shall determine whether a client has the necessary experience and knowledge to understand the risks in relation to the investment product or service offered or demanded when assessing whether an investment service is appropriate for a client (ESMA35 -36 -1640 - Section 2.3)",
            "warnings_to_clients": "Relevant. It is necessarty to warn clients where needed. In accordance with Article 25 (3) of MiFID II, a firm shall warn its client or potential client where it considers, on th e basis of the information received in relation to the clientu2019s knowledge and experience, that the investment product or service is not appropriate to the client or potential client. In addition, when clients or potential clients did not provide the requested information about their knowledge and experience, or when they provided insufficient information, the firm shall warn them that it is not in a position to determine whether the investment product or service envisaged is appropriate for them (ESMA35 -36 -1640 - Section 2.4)",
            "qualifications_of_firms_staff": "Relevant. Under Article 21(1)(d) of the MiFID II Delegated Regulation , firms are required to employ personnel with the skills, knowledge and expertise necessary for the discharge of the responsibilities allocated to them (ESMA35 -36 -1640 - Section 2.5)",
            "record_keeping": "Relevant. In accordance with Article 16(6) of MiFID II, firms shall arrange for records to be kept of all ser vices, activities and transactions undertaken by it which shall be sufficient to enable the competent authority to fulfil its supervisory tasks and to perform the enforcement actions under MiFID II, MIFIR. In addition, Article 56 of the MiFID II Deleg ated Regulation provides for a number of record -keeping obligations which are specific to the assessment of appropriateness (ESMA35 -36 -1640 - Section 2.6)"
        }
    }
}