{
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": "Derivative use for hedging and efficient portfolio management, but not central to strategy; no embedded derivatives, no leverage, no swaps, no inverse features, no complex indices, no contingent convertible bonds, no structured products, no capital protection, no opaque index, no significant securities lending, no roll costs or contango/backwardation effects.",
    "classification": "non-complex",
    "supporting_data": "The Franklin Sustainable Euro Green Corp 1-5 Year UCITS ETF is a UCITS-compliant, physically replicating ETF investing primarily in European corporate green bonds with a short to mid duration. It may use derivatives for hedging, efficient portfolio management, and investment purposes, but there is no evidence that derivatives are central to the investment strategy or that the fund uses synthetic replication, swaps, leverage, or inverse strategies. The fund does not invest in complex bonds (e.g., contingent convertibles), structured products, or opaque indices. The benchmark is a transparent, well-documented bond index. The fund is available to retail investors with basic investment knowledge, and its structure, risks, and objectives are described in clear, accessible language. Under MiFID II, all UCITS are automatically non-complex unless they are structured UCITS or employ complex portfolio management techniques that make the product difficult for the average retail investor to understand[1][2]. There is no indication that this ETF is a structured UCITS or that its derivative use introduces material complexity or opacity. Therefore, it meets the criteria for a non-complex UCITS ETF under MiFID II."
}