{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The iShares MSCI EM ESG Enhanced UCITS ETF USD (Dist) is a UCITS-compliant ETF that aims to replicate the MSCI EM ESG Enhanced Focus CTB Index by physically holding the underlying equity securities in similar proportions. The fund uses derivatives only for direct investment purposes to produce a similar return to its index, but this use is limited and not integral to the replication strategy, indicating derivatives are used for efficient portfolio management rather than as a core element. The ETF employs physical replication, which is transparent and straightforward for retail investors to understand. There is no indication of embedded derivatives, leverage beyond UCITS limits, or complex structured products such as CLOs or synthetic replication. Securities lending is used but is a secondary feature with collateral and revenue sharing, which does not automatically trigger complexity. The underlying index is transparent, based on ESG criteria applied to a well-known emerging markets equity index. The risk profile is driven by market volatility typical of emerging markets equities, not structural complexity. According to MiFID II Article 25(4)(a)(iv) and Article 57 of the Commission Delegated Regulation, UCITS ETFs that physically replicate transparent indices and use derivatives only for efficient portfolio management with minimal risk impact are classified as non-complex. ESMA and regulatory guidance confirm that synthetic or structured UCITS ETFs or those investing in complex derivatives or structured products (e.g., CLOs) would be complex, but this fund does not exhibit such features. Therefore, the ETF is classified as non-complex under MiFID II appropriateness rules."
}