{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Use of derivatives for portfolio management; active management with thematic rules-based ESG and factor exposures; no synthetic replication or embedded derivatives; no leverage beyond UCITS limits; transparent index references",
    "classification": "non-complex",
    "supporting_data": "The fund is a UCITS ETF, which under MiFID II is generally presumed non-complex. It invests primarily in a dynamic selection of listed US equities using a proprietary quantitative model applying ESG and factor-based filters. The ETF does not appear to use synthetic replication or embedded derivatives; derivatives use, if any, is limited to efficient portfolio management consistent with UCITS rules. There is no indication of leverage beyond UCITS limits or complex structured products like CLOs. The replication method is physical, holding underlying equities. The index referenced (Solactive GBS United States Large & Mid Cap Index NTR) is transparent and straightforward. The risk profile is high due to equity exposure but this reflects market risk, not structural complexity. According to MiFID II Article 25(4)(a)(iv) and Article 57 criteria, such a UCITS ETF with physical replication and limited derivative use for EPM is classified as non-complex. ESMA guidance confirms that synthetic ETFs or those with embedded derivatives or leverage would be complex, but this fund does not exhibit those features. Therefore, no appropriateness test beyond standard UCITS investor protections is required."
}