{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The asset is a UCITS ETF, which under MiFID II is generally presumed non-complex due to strict regulatory requirements ensuring diversification, liquidity, and transparency[1]. The ETF uses a sampling strategy with portfolio optimization to track the MSCI ACWI Universal Low Carbon Select 5% Issuer Capped with Developed Markets 100% Hedged to CHF Index, which is a transparent equity index. The ETF employs physical replication by holding a representative sample of the index's underlying securities rather than synthetic replication or total return swaps, which supports a non-complex classification[2]. Although the ETF uses currency forwards to hedge currency risk, this derivative use is limited to efficient portfolio management (EPM) purposes and does not significantly impact the risk-return profile, so derivatives are not considered integral to the investment objective[2]. The fund explicitly states it will not enter into securities lending, and there is no significant leverage beyond UCITS limits[2]. The risk profile is high due to equity market volatility but this reflects market risk rather than structural complexity[2]. There are no embedded derivatives or structured products such as CLOs involved. According to MiFID II Article 25(4)(a)(iv) and Article 57 criteria, UCITS ETFs that do not embed derivatives as a core strategy and track transparent indices physically are non-complex[1][2]. Therefore, this ETF is classified as non-complex under MiFID II. No comprehension alert is required in the PRIIPs KID."
}