{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "physical",
        "derivatives": false,
        "swaps": false,
        "leverage": false,
        "inverse": false,
        "complex_factors": [],
        "classification": "non-complex",
        "supporting_data": "The ETF aims to achieve its objective by investing in equity securities that make up the STOXX Global Smart City Infrastructure Index. This is described as passive management. The index methodology is based on revenue from specific sectors related to smart cities and infrastructure, with criteria for market capitalization and trading volume. While ESG criteria are considered for direct investment, indirect exposure via financial derivative instruments is mentioned, but the primary investment strategy is physical replication of an equity index. The document explicitly states that the ETF is passively managed and aims to invest in equity securities that make up the index, indicating a physical replication strategy. There is no mention of synthetic replication or the use of derivatives as core components of the investment strategy. The risks described are standard market risks, with no indication of complex derivative structures, leverage, or other features that would typically lead to a complex classification under MiFID II. The index composition and methodology, while specific to a theme, appear transparent and understandable for retail investors interested in that theme. Securities lending is mentioned, but as a cost-reduction measure, not a primary strategy, and within UCITS rules with collateral. The risk profile is rated six, but this is due to investment risk concentrated in specific sectors and the nature of equities, not structural complexity. The reference to CESR/09-295 and ESMA's guidance confirms that UCITS are generally presumed non-complex. Given the physical replication, clear investment objective, and lack of embedded complex instruments or derivative strategies, the ETF is classified as non-complex."
    }
}