{
    "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 asset is classified as non-complex based on the MiFID II framework. It is a UCITS ETF, which carries a presumption of non-complexity. The replication method is 'Direct Replication', a form of physical replication, meaning the fund holds the underlying securities of the index. This structure is transparent and straightforward for a retail investor to understand. While the KIID states that derivatives may be used, their purpose is explicitly limited to 'efficient portfolio management' (EPM) such as managing inflows and outflows, not for achieving the investment objective itself. This ancillary use does not make the product structurally complex. Similarly, the use of securities lending is a secondary activity managed under strict UCITS collateralization rules and does not make the ETF complex. The underlying index, while having a specific ESG and Paris-Aligned methodology, is transparent and based on large and mid-cap European equities, not on complex instruments. The main risks are market risks, which are typical for equity investments and do not equate to structural complexity. As per the CESR guidelines (IV Section 3, paragraph 69), all investments in UCITS are non-complex by definition for the purposes of the appropriateness requirements, and this presumption is not overturned by the features present in this ETF."
    }
}