{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The fund is a UCITS ETF, which under MiFID II is generally presumed non-complex due to strict regulatory requirements ensuring diversification, liquidity, and transparency. The ETF tracks the S&P 500 Scored & Screened Hedged to EUR Index using a passive management approach. The replication method is physical, holding underlying securities rather than synthetic replication. The fund may use derivatives only for risk reduction, cost reduction, or income generation, but this use is limited and for efficient portfolio management (EPM), not integral to the investment objective, thus not triggering complexity. The fund explicitly states it will not engage in securities lending, and there is no significant leverage beyond UCITS limits. The index tracked is transparent and broad-based, focusing on ESG criteria but without complex derivative overlays. The risk profile is high due to equity market volatility but this does not imply structural complexity. The fund's structure and risks are straightforward and understandable by retail investors with basic knowledge. Therefore, according to MiFID II Article 254, Delegated Regulation EU 2017/565 Article 57, and ESMA guidelines, this UCITS ETF is classified as non-complex. No embedded derivatives or structured products like CLOs are held. No features such as leverage, inverse strategies, or complex derivatives are present. The derivatives use is limited to EPM and does not affect the risk-return profile materially, so 'derivatives' is marked false in the context of complexity assessment. This aligns with ESMA and CESR guidance that physical replication UCITS ETFs with limited derivative use for EPM are non-complex. Hence, no appropriateness test is required for execution-only sales under MiFID II for this product."
}