{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "leverage": false,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthethic",
        "complex_factors": "The ETF invests in shares from the FTSE Developed Europe ESG Low Carbon Select Index and may use total return swaps and contracts for difference to achieve its objective, introducing counterparty and collateral risk.",
        "classification": "complex",
        "supporting_data": "The HSBC EUROPE SUSTAINABLE EQUITY UCITS ETF aims to track the FTSE Developed Europe ESG Low Carbon Select Index and may use derivatives such as total return swaps and contracts for difference for investment purposes. These are not used for efficient portfolio management purposes, which introduces counterparty, liquidity and collateral risks beyond the risk profile of a typical UCITS. The fund also uses securities lending, though this does not dominate the risk profile or the determination of MiFID II classification. Based on ESMA guidance, any derivative use makes an asset complex. The investment policy states that the ETF can invest up to 10% of its assets in total return swaps and contracts for difference and this makes it complex under MiFID II. This has been clearly stated by ESMA in its Supervisory Briefing of Appropriateness and execution-only. Furthermore, the index is based on a subset of the FTSE Developed Europe Index and, although it is transparent, the use of total return swaps leads to opacity regarding the precise portfolio holdings. Also, the fund has exclusions related to the environment and social factors but, due to the use of derivatives, and contracts for difference, it is difficult for a retail investor to understand this particular structure. Therefore, it is complex.",
        "ESMA_reference": "ESMA35-36-1640, Article 25(3) MiFID II and Article 57 of the MiFID II Delegated Regulation, ESMA Guidelines on complex debt instruments and structured deposits dated 4 February 2016."
    }
}