{
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": "None",
    "classification": "non-complex",
    "supporting_data": "The Xtrackers MSCI Global SDG 12 Circular Economy UCITS ETF is a UCITS-compliant, passively managed ETF that aims to track the performance of a transparent, well-documented equity index (MSCI ACWI IMI SDG 12 Responsible Consumption and Production Select Index) using physical replication. The fund may use derivatives for efficient portfolio management (EPM) purposes, such as managing inflows/outflows, hedging currency risk, or reducing transaction costs, but derivatives are not integral to the investment objective or strategy. The fund's structure, risks (primarily market volatility and tracking error), and investment policy are straightforward and easily understood by retail investors with basic knowledge. There is no significant leverage, no use of swaps or synthetic replication, no inverse or leveraged strategy, and no embedded derivatives or complex features that would introduce opacity or advanced risks. The fund is authorized in Ireland and regulated by the Central Bank of Ireland, meeting all UCITS requirements for diversification, liquidity, and transparency. Under MiFID II, all UCITS are automatically non-complex unless they employ complex portfolio management techniques or structured features that make the product difficult to understandu2014neither of which applies here[1]. The fund's documentation clearly states that any derivative use is limited to EPM and does not dominate the risk profile. Therefore, the ETF is classified as non-complex under MiFID II."
}