{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The Vanguard ESG North America All Cap UCITS ETF is a UCITS-compliant fund that employs a passive, physical replication strategy by investing directly in the underlying securities of the FTSE North America All Cap Choice Index. The fund uses derivatives only for limited purposes such as risk reduction or cost efficiency, not as an integral part of its investment objective, and these uses are minimal and consistent with efficient portfolio management. There is no indication of synthetic replication, embedded derivatives, leverage beyond UCITS limits, or complex structured products such as CLOs within the fund's holdings. The index tracked is transparent and based on market-cap weighted stocks screened for ESG criteria, which does not introduce structural complexity. The risk profile reflects market volatility and currency risk, typical for equity ETFs, without additional complexity from derivative or leverage features. According to MiFID II Article 25(4)(a)(iv) and Article 57 of the Commission Delegated Regulation, UCITS ETFs that physically replicate transparent indices and use derivatives only for efficient portfolio management with minimal risk impact are classified as non-complex. ESMA guidance and CESR technical advice confirm that such UCITS ETFs do not require an appropriateness assessment for non-advised sales. Therefore, this ETF is classified as non-complex under MiFID II."
}