{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Active management, use of financial derivative instruments (FDIs) for investment purposes and risk reduction, potential for market leverage via FDIs, quantitative models for stock selection, ESG screening, counterparty risk from derivatives and securities lending",
    "classification": "non-complex",
    "supporting_data": "The fund is a UCITS ETF, which is generally presumed non-complex under MiFID II Article 25(4)(a)(iv)[1]. The ETF is actively managed and uses quantitative models for stock selection, which introduces some complexity, but this does not automatically make it complex under MiFID II. The fund may use financial derivative instruments (FDIs) for investment purposes and to reduce risk, and may generate market leverage via FDIs. However, the use of derivatives is within the scope of UCITS rules and is not central to the fund's strategy in a way that would make the structure or risks difficult for a retail investor with basic knowledge to understand. The fund does not use swaps or synthetic replication, and there is no indication of embedded derivatives, contingent convertible bonds, or other features that would automatically trigger a complex classification. The fund's risk profile is elevated due to market volatility and active management, but this reflects market risk rather than structural complexity. Securities lending is present but is a secondary feature, well-managed within UCITS rules, and does not dominate the risk profile. The fund's structure, risks, and objectives are transparent and described in the KID, supporting a non-complex classification. There is no evidence of significant leverage beyond UCITS limits, embedded options, or opaque features that would override the UCITS presumption of non-complexity[1]. The fund's complexity is primarily due to active management and derivative use for efficient portfolio management, not due to structural features that would make it difficult for a retail investor to understand the risks involved."
}