{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "complex_factors": [
        "Currency hedging using derivatives",
        "ESG screening complexity"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication for its core strategy, investing directly in equity securities that make up the MSCI USA ESG Screened Index. While it uses financial derivative instruments (FDIs) for currency hedging, this is a common practice in ETFs and does not significantly alter the risk profile. The ESG screening criteria add some complexity to the index construction, but this does not make the underlying investments inherently complex. The fund's risk profile is rated 6, which is moderate, and the use of derivatives is limited to hedging rather than for leverage or inverse exposure. The PRIIPs KID confirms the physical replication method and the use of derivatives only for hedging purposes. The fact sheet further supports this, showing a straightforward equity portfolio with no leverage or synthetic replication. The main complexity factors are the ESG screening and currency hedging, but these do not meet the MiFID II thresholds for complexity.",
    "confidence": 90,
    "counter_argument": "Some might argue that the ESG screening adds complexity, but the underlying investments remain straightforward equities. The currency hedging is a standard practice and does not introduce significant additional risk. The fund's transparency and liquidity further support the non-complex classification.",
    "overriding_reason": "The primary factors driving the non-complex classification are the physical replication method, the absence of leverage or inverse exposure, and the straightforward equity investments. The use of derivatives is limited to hedging and does not materially alter the risk profile."
}