{
    "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 asset is classified as a UCITS ETF, which is explicitly presumed non-complex under MiFID II. The MiFID II complexity assessment rules state that UCITS ETFs are generally presumed non-complex due to their strict regulatory requirements. Furthermore, ESMA guidance (CESR/09-295, Section 3, Paragraph 69 and Annex I) explicitly states that 'All investments in UCITS are non-complex instruments by definition, for the purposes of the appropriateness requirements, regardless of the underlying instruments in which the UCITS invests. Nothing in MiFID Art.19(6) requires a person to look through to the underlying investments of the UCITS for these purposes.' It further clarifies that 'the fact that an undertaking invests in derivatives will not automatically make it complex'.The ETF uses physical replication by holding the underlying equity securities of the index, which is a transparent and straightforward method supporting a non-complex classification. While the fund may use derivative financial instruments (FDIs) 'to help achieve the Fundu2019s investment objective', this is understood to be for efficient portfolio management (EPM) purposes rather than integral to its core replication strategy (which is physical). The mention of 'Counterparty Risk' in the KII related to derivatives confirms their use but does not, in the context of a UCITS physically replicating ETF, automatically render the fund complex, especially given ESMA's explicit stance on UCITS and derivative use. Securities lending is also disclosed, which introduces counterparty risk but is a common EPM activity for UCITS ETFs and does not typically trigger a complex classification.The underlying index (MSCI USA SRI Select Reduced Fossil Fuel Index) is a transparent, well-documented equity index with specific ESG screening and weighting criteria. It does not involve complex financial engineering, illiquid assets, or mechanisms like roll costs, contango, or backwardation effects that would imply a complex structure difficult for a retail investor to understand. The risk rating of six out of seven reflects market volatility and ESG-related investment universe reduction, not structural complexity of the fund itself. There is no indication of significant leverage, embedded derivatives as a core strategy, or capital protection features that would complicate its understanding. The ETF is not a 'structured UCITS' as defined by ESMA (ESMA35-36-1640), which would be the only exception to the UCITS non-complex presumption."
    }
}