{
    "complex": false,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The SPDR S&P U.S. Consumer Discretionary Select Sector UCITS ETF (Acc) is classified as non-complex under MiFID II based on the following analysis: 1. Replication Method: The fund uses physical replication to track the S&P Consumer Discretionary Select Sector Daily Capped 25/20 Index, as confirmed in both the KIID and fact sheet. There is no mention of synthetic replication or swap agreements. 2. Leverage/Inverse Exposure: The fund does not employ any leverage or inverse strategies, and its performance is directly tied to the underlying index. 3. Underlying Assets: The fund invests in large, liquid U.S. consumer discretionary companies within the S&P 500, with no exposure to complex or illiquid assets. 4. Risk Profile: The fund's risk category (7) reflects the volatility of the underlying sector, not the complexity of the fund structure. 5. Derivative Usage: While the KIID mentions the potential use of financial derivative instruments for portfolio management, the fact sheet clarifies that the fund uses physical replication. Any derivative usage appears to be minimal and for efficient portfolio management, not as a core strategy. 6. UCITS Compliance: The fund is UCITS-compliant, which inherently limits the use of complex strategies. 7. Transparency: The fund provides clear, transparent information about its holdings, strategy, and risks, making it suitable for retail investors.",
    "confidence": 95
}