{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivative use for hedging and investment, active management, potential for complex underlying bonds",
    "classification": "non-complex",
    "supporting_data": "The Franklin Sustainable Euro Green Bond UCITS ETF is a UCITS-compliant ETF, which is automatically classified as non-complex under MiFID II Article 25(4)(a)(iv), unless it is a 'structured UCITS' or fails the Article 57 criteria[1]. The fund invests mainly in green bonds, with up to 25% in climate-aligned bonds, and may use derivatives for hedging, efficient portfolio management, and investment purposes. The fund is actively managed and does not seek to track its benchmark index, but there is no evidence of synthetic replication, significant leverage, or embedded swaps. The use of derivatives is disclosed but is not central to the fund's strategyu2014it is for hedging and efficient portfolio management, not for synthetic replication or complex payoff structures. The underlying bonds are standard green and climate-aligned bonds, not complex structured products like CLOs or contingent convertible bonds. The fund's structure, risks, and objectives are transparent and described in the KID. There is no indication of contingent bonds, swaps as a core strategy, or complex indices. The fund is listed and traded on stock exchanges, providing liquidity. Based on the available information, the fund does not exhibit features that would override the UCITS presumption of non-complexity under MiFID II[1]. Therefore, it is classified as non-complex, but the presence of derivative use for hedging and investment, as well as active management, should be noted as factors that could, in certain circumstances, contribute to complexity if their impact on risk or structure were more significant."
}