{
    "complex": false,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The UBS (Lux) Fund Solutions - MSCI USA Socially Responsible UCITS ETF is a physically replicated ETF that tracks the MSCI USA SRI Low Carbon Select 5% Issuer Capped 100% hedged to EUR Index (Net Return). The KIID and factsheet confirm that the fund uses physical replication, meaning it directly holds the underlying securities of the index. There is no indication of synthetic replication, leverage, or inverse strategies. The fund does not use derivatives for purposes other than efficient portfolio management (e.g., currency hedging via forwards), which is permitted under MiFID II without triggering complexity. The risk profile is transparent, with a risk category of 6 due to equity market volatility, but this is typical for equity ETFs and does not imply complexity. The fund is UCITS-compliant, further supporting its non-complex classification. The factsheet explicitly states the replication methodology as 'Physical (Full replicated),' reinforcing the non-complex nature of the product.",
    "confidence": 95,
    "counter_argument": "While the fund uses currency forwards for hedging, this is a standard practice for hedged ETFs and does not introduce complexity under MiFID II. The absence of leverage, inverse strategies, or synthetic replication further supports the non-complex classification. The fund's ESG focus does not add complexity, as it is a standard thematic approach within a transparent index-tracking framework."
}