{
    "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 Europe Health Care Screened UCITS ETF (1C) is classified as non-complex under MiFID II based on the following analysis: 1. Physical Replication: The factsheet explicitly states the fund uses 'Direct Replication (physically)' to track the MSCI Europe Health Care Screened 20-35 Select Index. 2. No Derivative Usage: While the KIID mentions the fund 'may use derivatives for investment purposes,' the factsheet confirms no derivatives are currently used (no swap exposure or synthetic replication). 3. Straightforward Strategy: The fund's objective is to replicate a transparent, rules-based index of large/mid-cap European healthcare equities with ESG screening. 4. UCITS Compliance: The fund is UCITS-compliant, which inherently limits complexity. 5. Risk Profile: The risk profile (category 6) is consistent with equity ETFs and clearly disclosed. 6. No Leverage/Inverse Features: No leverage, inverse exposure, or capital protection mechanisms are present. 7. Liquidity: The fund is listed on major exchanges (London, Xetra, Stuttgart) with daily liquidity. The only potential complexity factor is the index's ESG screening and GHG intensity rules, but these are standard for thematic ETFs and do not trigger MiFID II complexity. The absence of derivatives, leverage, or synthetic structures, combined with the fund's transparent physical replication and UCITS status, supports the non-complex classification.",
    "confidence": 95
}