{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivative use for investment purposes, including up to 10% in total return swaps and contracts for difference; securities lending up to 30% of assets; ESG index with exclusions and constraints",
    "classification": "non-complex",
    "supporting_data": "The ETF is a UCITS-compliant, physically replicated fund tracking a transparent, ESG-focused real estate index. While it may use derivatives (up to 10% of assets, primarily for efficient portfolio management and to gain exposure when direct investment is not possible or practical), this use is limited and not central to the investment objective. Securities lending is permitted but capped and managed within UCITS rules. The index methodology is public and the fundu2019s structure, risks, and objectives are clearly disclosed. There is no significant leverage, no embedded derivatives, and no complex payout structures. The risks described (market, liquidity, operational, counterparty) are typical for equity ETFs and do not introduce structural complexity beyond what a retail investor with basic knowledge could understand. Under MiFID II, UCITS ETFs are generally presumed non-complex unless they employ complex strategies or structures that make the product difficult to understandu2014which is not the case here, as derivative use is ancillary and well-disclosed, and the replication method is physical[1]. The presence of limited derivative exposure for efficient portfolio management and securities lending does not, in this context, override the UCITS presumption of non-complexity, provided these features are secondary, well-managed, and clearly explained to investors[1]. If the derivative exposure were integral to the strategy (e.g., synthetic replication or significant use of complex derivatives), the classification would likely be complex, but this ETFu2019s use is within typical UCITS limits and for ancillary purposes."
}