{
    "fund_name": "Xtrackers MSCI Global SDG 3 Good Health UCITS ETF",
    "isin": "IE00036F4K40",
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [
        "Complex index methodology (SDG 3 screening criteria)",
        "Potential derivative usage for risk management (though not primary strategy)",
        "Exposure to emerging markets and small/mid-cap companies"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication to track the MSCI ACWI IMI SDG 3 Good Health and Well-being Select Index. While the index has complex ESG screening criteria, the fund itself does not use derivatives as a core strategy. The factsheet confirms 'Direct Replication (physically)' as the portfolio methodology. The KIID mentions derivatives may be used for risk management but not as a primary investment tool. The risk profile (category 6) reflects the underlying equity market exposure rather than derivative complexity. The fund is UCITS-compliant, has low ongoing charges (0.35%), and no leverage or inverse exposure. While the index methodology is sophisticated, the fund's structure remains straightforward for retail investors.",
    "confidence": 90,
    "counter_argument": "The index's complex ESG screening could be seen as a complexity factor, but MiFID II guidance suggests that index complexity alone does not automatically make the fund complex if the replication method is transparent and the risks are clearly disclosed. The physical replication method and lack of derivative-driven strategy outweigh the index complexity in this case.",
    "risk_profile": "Category 6 (high risk) due to equity market exposure, but not due to derivative or structural complexity"
}