{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": "The ETF tracks an ESG index, meaning the underlying index may be complex due to ESG criteria and exclusion rules.",
        "classification": "non-complex",
        "supporting_data": "The Xtrackers MSCI Europe ESG UCITS ETF is presumed non-complex under MiFID II. The ETF uses physical replication to track the MSCI Europe Low Carbon SRI Selection Index. The fund invests in equities, and the risk profile is 6/7, reflecting market volatility. The index is rules-based and uses ESG screening criteria, which introduces a degree of complexity compared to standard indices. Although the index administrator and MSCI ESG Research LLC will be responsible for screening it does include ESG risks and criteria which retail clients may not easily understand. The fund may also use derivatives for efficient portfolio management (EPM), which is acceptable if impact is minimal, so this is not a factor in determining complexity. The fund has no leverage."
    }
}