{
    "success": true,
    "data": {
        "complex": false,
        "leverage": false,
        "derivates": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "ESG criteria",
            "Derivative use for optimization",
            "Transparency of Underlying Index"
        ],
        "classification": "non-complex",
        "supporting_data": "The ETF tracks the MSCI Europe ESG Enhanced Focus CTB Index.  It's a passive UCITS ETF, meaning it aims to replicate the index's performance through physical replication, a strategy generally considered non-complex under MiFID II.  While the index provider's exclusionary criteria are complex, they are not an integral part of the ETF's methodology.  The index is described as actively managing ESG features, and these features are likely to result in investment decisions, even in the selection of the securities in the index itself.  The prospectus does reference the possible use of derivative instruments for direct investment purposes, but the usage of these derivatives is limited to optimization (e.g., managing inflows/outflows, hedging currency risk, or reducing transaction costs).  This falls in line with the criteria that allows the instrument to be deemed non-complex. Therefore, the ETF, while incorporating ESG criteria which themselves may be considered to contain some level of complexity, and referencing derivatives to optimize the investment, is overall a non-complex product under MiFID II guidelines.  No significant leverage, embedded derivatives, or opaque features are mentioned."
    }
}