{
    "complex": false,
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Currency hedging using derivatives",
        "ESG index complexity",
        "Securities lending"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication for its core investment strategy, tracking the MSCI USA ESG Enhanced Focus CTB Index through direct equity holdings. While it uses derivatives for currency hedging (FX forward contracts) and may engage in securities lending, these activities are common in UCITS-compliant ETFs and do not materially alter the fund's risk profile. The index itself, while incorporating ESG criteria, is a standard equity index without leverage or complex structured features. The fund's risk profile (rated 6) is typical for equity ETFs and does not indicate complexity beyond standard market risks. The KIID and PRIIPs documents do not contain any 'comprehension warnings' or language suggesting the product is unsuitable for retail investors. The use of derivatives is limited to hedging and does not involve swaps or synthetic replication, and there is no leverage or inverse exposure. The fund's transparency, liquidity, and straightforward investment strategy align with MiFID II's criteria for non-complex products.",
    "confidence": 90
}