{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivatives, Swaps, Counterparty Risk",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is authorized under the UCITS Directive and is therefore automatically classified as non-complex under MiFID II Article 25(4)(a)(iv), regardless of its underlying investments[1]. The ETF uses physical replication to track a transparent equity index (FTSE USA ESG Low Carbon Select Index), which supports a non-complex classification. While the ETF may use derivatives (including up to 10% in total return swaps and contracts for difference, though not expected to exceed 5%) for efficient portfolio management and investment purposes, this does not automatically make it complex under MiFID II, as UCITS are presumed non-complex unless they are specifically structured UCITS with algorithm-based payoffs or similar complex features, which is not the case here[1]. The ETF does not use significant leverage, does not embed complex options or capital protection features, and does not track a complex or opaque index. Securities lending is permitted but is not expected to dominate the risk profile. The main risks disclosed (counterparty risk, derivatives risk, liquidity risk) are typical for UCITS ETFs and do not, in themselves, trigger a complex classification under MiFID II for UCITS. The structure, risks, and investment policy are transparent and consistent with UCITS regulations, supporting the view that a retail investor with basic knowledge can understand the ETF's risks and performance drivers."
}