{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivatives, Swaps, Counterparty Risk",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is authorised under the UCITS Directive and is therefore automatically classified as non-complex under MiFID II Article 25(4)(a)(iv), regardless of its underlying investments[1]. The ETF uses physical replication to track a transparent equity index (FTSE UK ESG Low Carbon Select Index), which is straightforward and easily understood by retail investors. While the ETF may use derivatives (including up to 10% in total return swaps and contracts for difference, though typically less than 5%) for efficient portfolio management and to gain exposure when direct investment is not possible, this use is ancillary and not central to the ETFu2019s investment objective. The ETFu2019s structure, risks (market volatility, tracking error), and investment policy are clearly disclosed and typical of a passive, index-tracking UCITS ETF. There is no significant leverage, no embedded derivatives, and no complex features such as capital protection or contingent convertibles. Securities lending is permitted up to 30% of assets (typically less than 25%), but this is a secondary activity, well within UCITS rules, and does not dominate the risk profile. The ETF does not track a complex or opaque index, and its risk indicator (6/7) reflects market risk, not structural complexity. Counterparty risk from derivatives and securities lending is disclosed but does not alter the non-complex classification, as UCITS are presumed non-complex unless they are structured UCITS (which this is not)[1]. The ease of understanding for a retail investor with basic knowledge is high, given the ETFu2019s passive, transparent, and regulated nature. Therefore, despite some derivative use, the ETF remains non-complex under MiFID II."
}