{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [
        "Complex benchmark (MSCI World SRI EU PAB Overlay ESG Custom Index)",
        "Active management with potential for higher tracking error",
        "ESG screening and sustainability criteria may add complexity"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication and does not employ leverage, inverse strategies, or swaps. While the benchmark is complex (custom ESG-aligned index), the ETF's active management approach does not introduce additional complexity beyond what is typical for a UCITS-compliant ETF. The use of derivatives is limited to efficient portfolio management, and the risk profile is clearly disclosed. The PRIIPs KID and factsheet confirm no derivative or swap usage beyond standard hedging. The ETF's Article 9 SFDR classification indicates a sustainable investment objective, but this does not inherently make it complex under MiFID II. The absence of a 'comprehension warning' in the PRIIPs KID further supports the non-complex classification.",
    "confidence": 90
}