{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivatives for efficient portfolio management and investment purposes, up to 10% in total return swaps and contracts for difference (not expected to exceed 5%); securities lending up to 30% of assets (not expected to exceed 25%); high concentration in benchmark index; ESG exclusions and sustainability focus may add complexity for some retail investors.",
    "supporting_data": "The ETF is a UCITS-compliant, physically replicating fund tracking a transparent equity index (FTSE Developed Europe ex UK ESG Low Carbon Select Index). It may use derivatives (including total return swaps and contracts for difference) for efficient portfolio management and investment purposes, but not as a core replication strategy. Securities lending is permitted but limited. The fund is passively managed, listed, and offers daily liquidity. The risk profile is high (category 6/7) due to market volatility, not structural complexity. The use of derivatives, while limited, introduces counterparty risk and potential complexity, but the overall structure remains straightforward for retail investors with basic knowledge. The fund does not use significant leverage, embedded derivatives, or synthetic replication. The index is transparent, but the fund's ESG exclusions and sustainability focus may require additional understanding from investors.",
    "classification": "non-complex"
}