{
    "success": true,
    "data": {
        "type": "ETF",
        "ucits": true,
        "replication_method": "physical",
        "derivatives": false,
        "swaps": false,
        "leverage": false,
        "inverse": false,
        "complex_factors": [],
        "classification": "non-complex",
        "supporting_data": "The ETF tracks the MSCI Europe Materials Screened 20-35 Select Index, which is based on the MSCI Europe Materials Index and includes ESG screening and a carbon emission reduction rule. The KIID states the fund is passively managed and aims to reflect the performance of the index. It employs physical replication by buying a substantial number of securities in the index. The use of derivatives is mentioned as a possibility for risk management, cost reduction, and performance improvement, but not as integral to the investment objective. Securities lending is also mentioned as a way to generate additional income. The risk profile is rated as category 6 due to potential share price fluctuations, indicating market risk rather than structural complexity. The key nuances are that the replication is physical, the index methodology is relatively transparent (with ESG and carbon screening being understandable criteria), and while derivatives *may* be used, they are not central to the strategy. The ESMA guidance (CESR/09-295) clearly states that UCITS are generally considered non-complex. The KIID does not indicate any embedded derivatives or complex strategies. The risk and reward profile being category 6 is a measure of market volatility, not inherent product complexity. The mention of derivatives for EPM is standard and does not automatically trigger complexity if limited and for risk management purposes. Therefore, based on the provided information, the ETF falls under the presumption of non-complex."
    }
}