{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "ESG Screening",
            "Currency Hedging"
        ],
        "classification": "non-complex",
        "supporting_data": "The Xtrackers DAX ESG Screened UCITS ETF aims to reflect the performance of the DAX ESG Screened Index. The fund is passively managed and utilizes physical replication by buying a substantial number of securities in the index. It also enters into financial contracts to manage currency fluctuations, which are described as derivatives used to reduce exchange rate movements. While derivatives are mentioned, their use is for efficient portfolio management (hedging currency risk) rather than core index replication. The index itself is based on the DAX Index but with ESG screening criteria, which adds a layer of complexity to the index composition but not necessarily the ETF's structure. The KID states the fund aims to minimize foreign currency fluctuations at the share class level, indicating a currency hedge. The risk profile is categorized as 6 out of 7, indicating high volatility, but this is market risk, not structural complexity. Securities lending is mentioned as a possibility to generate income. Given the physical replication, limited derivative use for hedging, and a clearly defined index (albeit with ESG screening), the ETF is considered non-complex under MiFID II. The ESG screening and currency hedging are not considered to inherently make the ETF's structure or risks difficult for a retail investor to understand."
    }
}