{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [],
        "classification": "non-complex",
        "supporting_data": "The Xtrackers MSCI World Consumer Staples UCITS ETF is classified as non-complex primarily due to its UCITS compliant status and physical replication method. Under MiFID II Article 19(6) and as explicitly stated in CESR/09-295 Annex I Section 3, 'Units (or u2018sharesu2019) in any UCITS' are 'AUTOMATICALLY NON-COMPLEX'. This guidance further clarifies that 'the fact that an undertaking invests in derivatives will not automatically make it u2018complexu2019 for these purposes' (CESR/09-295, Section 3, Paragraph 78, and Annex I table). The fund's investment policy confirms physical replication, stating it 'will attempt to replicate the index... by buying all or a substantial number of the securities in the index.' This is a transparent and straightforward method. While the fund 'may employ techniques and instruments... including the use of financial contracts (derivatives)' for efficient portfolio management (EPM) such as managing risk, reducing costs, and improving results, this use of derivatives is not integral to its core index replication objective, which is physical. Consistent with the ESMA guidance for UCITS, this EPM derivative use does not, in itself, lead to a complex classification.Furthermore, the fund's engagement in securities lending is described as a means to 'generate additional income to offset the costs of the fund' and does not dominate the risk profile. As a secondary feature within the UCITS framework, this does not render the ETF complex. There is no indication of significant leverage, embedded derivatives within the product's structure (beyond EPM use), or the tracking of complex or opaque indices. The MSCI World Consumer Staples index is a transparent, well-documented equity index. The fund's risk indicator (5/7) is attributed to market volatility (share price fluctuations) rather than structural complexity, which is standard for equity ETFs and does not imply complexity under MiFID II."
    }
}