{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF is classified as non-complex under MiFID II based on the following analysis: 1) It uses physical replication (no synthetic replication or swap agreements mentioned), 2) It does not employ leverage or inverse strategies, 3) The investment strategy is straightforward (actively managed equity portfolio with ESG focus), 4) The underlying assets are liquid, transparent equity securities, 5) The risk profile is clearly communicated (risk level 6/7, typical for equity ETFs), and 6) The fund is UCITS-compliant, which inherently limits complexity. The fact sheet confirms no securities lending or derivative usage beyond efficient portfolio management. While the fund uses derivatives for efficient portfolio management (as permitted under UCITS), this does not trigger complexity under MiFID II as it is not for leverage or risk transformation. The absence of swap counterparty risk, leverage, or inverse strategies further supports the non-complex classification.",
    "confidence": 95
}