{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "physical",
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "leverage": false,
        "complex_factors": [
            "ESG Screening Criteria"
        ],
        "classification": "non-complex",
        "supporting_data": "The ETF tracks the DAX ESG Screened Index, which is based on the DAX Index but applies environmental, social, and governance (ESG) screening criteria. The index methodology involves excluding companies that breach certain ESG standards and then weighting the remaining securities by their free-float adjusted market capitalization, with a cap of 15% on individual components. The investment policy states that the fund will attempt to replicate the index by buying all or a substantial number of the securities in the index. While the fund may employ 'techniques and instruments in order to manage risk, reduce costs and improve results' and 'may also engage in secured lending of its investments', these are generally considered to be for efficient portfolio management (EPM) and do not inherently make the ETF complex. The KIID indicates a risk and reward profile of category 6, which signifies a high likelihood of losses and gains due to strong share price fluctuations, but this is market risk and not indicative of structural complexity. The use of ESG criteria, while adding a layer of screening, does not, in itself, make the ETF's structure or payoff difficult for a retail investor to understand. The primary replication method is physical, holding underlying securities, which is considered non-complex. There is no mention of synthetic replication, embedded derivatives, or complex underlying instruments that would inherently classify this ETF as complex under MiFID II."
    }
}