{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The UBS (Irl) ETF plc - UBS MSCI USA Universal UCITS ETF is a physically replicated ETF that tracks the MSCI USA Universal Low Carbon Select 5% Issuer Capped Index. The KIID and fact sheet confirm that the fund uses physical replication (full replication) and does not use derivatives, swaps, or leverage. The fund's investment objective is straightforward, focusing on tracking an index with ESG characteristics. The risk profile is rated as 6 (high volatility), but this does not inherently make the fund complex under MiFID II. The fund does not have any capital protection mechanisms, inverse exposure, or other complex features. The use of derivatives is limited to efficient portfolio management, which is typical for ETFs and does not trigger complexity under MiFID II. The fund is UCITS compliant, which further supports its non-complex classification. The fact sheet and KIID do not mention any swap agreements, unfunded swaps, or counterparty risk beyond standard disclosures. The fund's holdings are transparent and consist of liquid, publicly traded equities, which are easily understandable by retail investors. The absence of complex structured products, contingent bonds, or other complex underlying assets further supports the non-complex classification.",
    "confidence": 95
}