{
    "ucits": true,
    "type": "ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": "None",
    "classification": "non-complex",
    "supporting_data": "The L&G US ESG Exclusions Paris Aligned UCITS ETF is a UCITS-compliant, physically replicated ETF that primarily invests directly in the securities of its benchmark index. While the fund may use financial derivative instruments (FDIs) for efficient portfolio management, there is no evidence that derivatives are central to the investment strategy or that the fund uses swaps, leverage, or inverse strategies. The fund's structure, objective, and risks are transparent and straightforward, and the underlying index is a well-documented, liquid equity index. The fund does not hold complex bonds, structured products, or other instruments that would make its risk profile difficult for a retail investor to understand. Under MiFID II, all UCITS are automatically non-complex unless they employ complex portfolio management techniques or structured features, which is not the case here[1]. The fund's documentation does not indicate any features that would override the UCITS presumption of non-complexity, such as synthetic replication, significant derivative exposure, or embedded complex options. Therefore, the fund meets all criteria for classification as a non-complex instrument under MiFID II."
}