{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "None",
    "classification": "non-complex",
    "supporting_data": "The fund is a UCITS ETF, which is automatically non-complex under MiFID II unless it is a structured UCITS or uses derivatives as a central part of its investment strategy[1]. The fund's objective is to track a transparent, ESG-screened equity index using physical replication, holding the underlying securities. While the fund may use derivatives for efficient portfolio management (EPM) to manage risk, reduce costs, or improve results, such use is ancillary and not central to the investment strategy. There is no evidence of synthetic replication, embedded derivatives, leverage beyond UCITS limits, or other complex features. The fund's structure, risks, and objectives are straightforward and disclosed in the KID, supporting a non-complex classification for the average retail investor[1][2]. The risk profile (category 6) reflects market volatility of emerging markets, not structural complexity. No comprehension alert is required."
}