{
    "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 AC World Screened UCITS ETF (1C) is classified as non-complex under MiFID II based on the following analysis:1. **Replication Method**: The fund uses physical replication (as confirmed in the factsheet: 'Portfolio Methodology: Direct Replication (physically)'), which is a non-complex indicator.2. **Derivative Usage**: While the KIID mentions the fund 'may employ techniques and instruments in order to manage risk, reduce costs and improve results,' the factsheet clarifies that the fund does not use swaps or synthetic replication. The derivative usage is limited to efficient portfolio management (e.g., hedging, reducing transaction costs), which does not trigger complexity under MiFID II.3. **Leverage/Inverse Exposure**: The fund does not employ leverage or inverse strategies, as confirmed by the absence of terms like 'leveraged,' 'inverse,' or 'gearing' in the documents.4. **Underlying Asset Complexity**: The fund invests in large and mid-cap equities from global developed and emerging markets, which are liquid and transparent. The ESG screening process does not introduce complexity, as it is rules-based and clearly disclosed.5. **Risk Profile**: The fund's risk rating is category 6 (out of 7), which is relatively high but not indicative of complexity. The risks are clearly explained and relate to market volatility, not structural or derivative-related risks.6. **Costs and Charges**: The fund has a straightforward fee structure (0.25% ongoing charges) with no performance fees or complex fee arrangements.7. **UCITS Compliance**: The fund is UCITS-compliant, which inherently limits the use of complex strategies.**Counterarguments and Override**:- The KIID mentions the fund 'may employ techniques and instruments in order to manage risk, reduce costs and improve results,' which could imply derivative usage. However, the factsheet explicitly states 'Direct Replication (physically),' overriding this concern.- The risk rating of 6 is high, but this reflects market risk, not structural complexity.**Conclusion**: The fund is non-complex because it uses physical replication, has no leverage or inverse exposure, and invests in liquid, transparent assets. The derivative usage (if any) is for efficient portfolio management and does not materially alter the fund's risk profile.",
    "confidence": 95
}