{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Xtrackers MSCI Innovation UCITS ETF uses physical replication to track the MSCI ACWI IMI Innovation Select Screened 200 Index. While the KIID mentions the potential use of derivatives for risk management and efficient portfolio management, there is no indication of synthetic replication, leverage, or complex underlying assets. The fund's risk profile (category 6) is primarily due to its exposure to innovative and emerging market equities rather than structural complexity. The ESG screening and thematic focus do not introduce additional complexity under MiFID II rules. The fund is UCITS-compliant, which generally aligns with non-complex classifications.",
    "confidence": 90,
    "counter_argument": "Some might argue that the use of derivatives for any purpose could trigger complexity. However, the derivatives are explicitly stated to be used for risk management and efficiency purposes, not as a core strategy, which aligns with standard ETF practices that do not classify as complex under MiFID II. The fund's transparency, liquidity, and straightforward replication method further support the non-complex classification."
}