{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The asset is a UCITS ETF, which under MiFID II is generally presumed non-complex due to strict regulatory requirements ensuring diversification, liquidity, and transparency. The ETF described pursues an actively managed equity strategy aligned with the MSCI Europe SRI EU PAB Overlay ESG Custom Index, investing primarily in European equities. It may use derivatives only for efficient portfolio management purposes, which is consistent with non-complex classification if derivatives are not integral to the investment objective and do not significantly alter the risk profile. There is no indication of synthetic replication or embedded derivatives such as swaps or structured products. The replication method appears to be physical, holding underlying securities directly. The ETF does not employ significant leverage beyond UCITS limits, nor does it have complex features like capital protection or opaque indices. The risk profile reflects market volatility typical of equity investments, not structural complexity. Transparency of the underlying index and the ETF's structure supports ease of understanding for retail investors with basic knowledge. Therefore, based on MiFID II Article 254, Delegated Regulation EU 2017/565 Article 57, and ESMA guidelines, this UCITS ETF is classified as non-complex."
}