{
    "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. The fund aims to replicate the MSCI EM Low Carbon SRI Selection Index by buying a portfolio of securities that may comprise the constituents of the index or other unrelated investments, indicating physical replication. The use of derivatives is mentioned only as a possibility for risk management or cost reduction, not as an integral part of the investment strategy, so derivative use is limited and for efficient portfolio management (EPM), which does not trigger complexity. There is no indication of synthetic replication or embedded derivatives such as swaps or structured products. The fund does not use significant leverage beyond UCITS limits. The index tracked is transparent and based on a well-known MSCI equity index with ESG criteria, supporting ease of understanding. The risk profile reflects market volatility typical of emerging markets but does not imply structural complexity. Therefore, the ETF meets the criteria for non-complex classification under MiFID II Article 25(4)(a)(iv) and Article 57 of the Delegated Regulation, as derivatives are not central to the strategy, replication is physical, and the structure and risks are straightforward for retail investors with basic knowledge. This aligns with ESMA and CESR guidance that UCITS ETFs with physical replication and limited derivative use for EPM are non-complex. Hence, no appropriateness assessment is required for execution-only sales, and no comprehension alert is needed in the KID."
}