{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The UBS MSCI USA Socially Responsible UCITS ETF is a UCITS-compliant ETF that uses physical replication by holding the underlying shares of the MSCI USA SRI Low Carbon Select 5% Issuer Capped Index, hedged to EUR. It does not engage in securities lending or significant leverage, and derivatives are only used for limited purposes such as currency hedging and efficient portfolio management, with no indication that derivatives are integral to the investment objective or that swaps or synthetic replication are used. The ETF's structure and risks (market volatility, tracking error) are straightforward and transparent, suitable for retail investors with basic knowledge. The ETF does not embed derivatives or complex structured products such as CLOs. According to MiFID II Article 25(4)(a)(iv) and Article 57 of the Delegated Regulation, UCITS ETFs that physically replicate transparent indices and use derivatives only for EPM with minimal risk impact are classified as non-complex. ESMA guidance confirms that synthetic ETFs or structured UCITS with embedded derivatives or complex strategies are complex, but this ETF does not fall into those categories. Therefore, no appropriateness assessment is required for execution-only sales, and no comprehension alert is mandated. This classification aligns with Janus Henderson's statement that all UCITS funds are automatically non-complex under MiFID II. The ETF's risk category (6/7) reflects market volatility, not structural complexity. No complex features such as leverage, embedded derivatives, or opaque indices are present. Hence, the ETF is non-complex under MiFID II rules."
}