{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivatives, Swaps, Efficient Portfolio Management (EPM) use, Counterparty Risk",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is physically replicated, tracking a transparent, well-documented equity index (MSCI World Value SRI ESG Target Select Index). While the fund may use derivatives (including up to 10% in total return swaps and contracts for difference, though typically less than 5%) and engage in securities lending (up to 30% of assets, typically less than 25%), these activities are for efficient portfolio management (EPM) purposesu2014such as managing inflows/outflows, hedging currency risk, or reducing transaction costsu2014rather than as a core part of the investment strategy. The use of derivatives is limited, well-disclosed, and does not dominate the risk profile. The fund does not employ significant leverage beyond UCITS limits, does not use synthetic replication, and does not embed complex options or structured products. The structure, risks (market volatility, tracking error, counterparty risk from derivatives and securities lending), and investment objective are transparent and can be understood by retail investors with basic knowledge. The fund is UCITS-compliant, which under MiFID II generally presumes non-complex status unless specific complex features are present[1]. Here, the limited and ancillary use of derivatives and swaps, combined with physical replication and a straightforward index, supports a non-complex classification, consistent with industry practice and regulatory guidance[1][2]. However, the presence of any derivative exposure means that, in a strict interpretation (especially by some regulators), the fund could be considered complex if derivative use is central to the strategy or introduces material opacity or risk beyond basic market exposure. In this case, the ancillary nature of the derivative use and the overall transparency of the fund structure justify the non-complex classification, but firms should monitor for any material change in strategy or risk profile that could alter this assessment."
}