{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [],
        "classification": "non-complex",
        "supporting_data": "The fund is explicitly identified as a UCITS ETF, which benefits from a strong presumption of non-complexity under MiFID II Article 19(6) (CESR/09-295, Section 3, Para 69). This presumption is reinforced by the ESMA guidelines (CESR/09-295, Annex I, Section 3) which state that for UCITS, 'None are automatically complex. (Note: the fact that an undertaking invests in derivatives will not automatically make it u2018complexu2019 for these purposes.)'.The replication method is physical, as the fund aims to track the index 'by buying a portfolio of securities that may comprise the constituents of the index'. This is a transparent and straightforward approach, avoiding the complexity associated with synthetic replication.Derivatives are mentioned as being used for 'efficient portfolio management' (EPM) purposes, specifically to 'manage risk, reduce costs and improve results'. The provided MiFID II rules clarify that derivative use limited to EPM with minimal impact on the risk-return profile supports a non-complex classification, distinguishing it from derivatives used integrally for the investment objective (e.g., synthetic replication). The KII does not explicitly mention 'swaps' by name or imply their use for integral replication. Given the fund's physical replication strategy, any derivative use (including potential swaps, if present though not named) would fall under EPM, which does not automatically trigger complexity for a UCITS fund.The underlying index (MSCI ACWI Select Screened Index) is a transparent, rules-based equity index, well-described in the KII regarding its composition and ESG screening criteria. This aids in the ease of understanding for retail investors.Additional features like securities lending are presented as a secondary activity to offset costs, not a dominant risk factor, and are generally permitted within UCITS frameworks without leading to complexity. There is no indication of significant leverage or the holding of complex underlying assets such as Contingent Convertible Bonds. The fund's risk rating (6/7) reflects market risk (volatility) inherent in equity investments, not structural complexity (as per MiFID II rules, 'Market risk alone doesn't make an ETF complex'). The fund is not a 'structured UCITS' with algorithm-based payoffs, which is a condition for complexity under more recent ESMA guidelines (ESMA35-36-1640, Section 2.1, Q-i-relation-to-investment-products-referred-to-in-the-fourth-indent-of-Article-25(4)-of-MiFID-II). There are no references to 'roll costs', 'contango', or 'backwardation effects', which are often indicators of complex, derivatives-heavy strategies, especially in commodity-linked products."
    }
}