{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Xtrackers MSCI Genomic Healthcare Innovation UCITS ETF (1C) is classified as non-complex under MiFID II based on the following analysis: 1. Replication Method: The fund uses physical replication (direct purchase of underlying securities) as confirmed in the factsheet ('Portfolio Methodology: Direct Replication (physically)'). 2. Derivative Usage: While the KIID mentions the fund 'may use derivatives for investment purposes and to try to manage its investments more efficiently,' this is a standard disclosure and does not indicate extensive or complex derivative usage. The factsheet does not mention swap agreements or synthetic replication. 3. Leverage/Inverse: No leverage or inverse exposure is indicated in either document. 4. Underlying Assets: The fund invests in global equities (large, medium, and small-cap) with ESG screening, which are straightforward and liquid assets. 5. Risk Profile: The fund is classified as risk level 6 (out of 7), but this reflects the inherent volatility of the healthcare innovation sector rather than structural complexity. 6. Costs: The ongoing charges are simple (0.30% TER) with no performance fees or complex fee structures. 7. UCITS Compliance: The fund is UCITS-compliant, which inherently limits complexity. The only potential complexity factor is the ESG screening methodology, but this is standard for thematic ETFs and does not trigger MiFID II complexity. The factsheet confirms the fund is 'ESG Screened' but does not indicate any complex structured products or contingent bonds. The absence of swap usage, leverage, or inverse strategies, combined with physical replication and straightforward equity exposure, supports the non-complex classification.",
    "confidence": 95
}