{
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": "None",
    "classification": "non-complex",
    "supporting_data": "The fund is a UCITS ETF, which is automatically classified as non-complex under MiFID II unless it is a structured UCITS or uses derivatives as a central part of its investment strategy[1]. This ETF tracks the MSCI ACWI Universal Low Carbon Select 5% Issuer Capped Index using physical replication (portfolio optimization/sampling), not synthetic replication or swaps. While the fund may use derivatives for efficient portfolio management (EPM) to reduce risk or manage inflows/outflows, such use is limited and not central to the investment objective. There is no securities lending, no significant leverage beyond UCITS limits, and no embedded derivatives or complex features. The index is transparent and the fund's structure, risks, and objectives are straightforward for retail investors to understand. The high risk category (6/7) reflects market volatility of equities, not structural complexity. Therefore, the fund meets all criteria for non-complex classification under MiFID II[1]."
}