{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivatives for efficient portfolio management, limited use of total return swaps and contracts for difference, securities lending",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is physically replicating a transparent, well-diversified equity index (FTSE Developed ESG Low Carbon Select Index). While it may use derivatives for efficient portfolio management (EPM) and up to 10% of assets in total return swaps and contracts for difference (not expected to exceed 5%), this use is limited, ancillary, and not central to the investment objective. The ETF may also engage in securities lending (up to 30% of assets, not expected to exceed 25%), but this is a secondary feature, well-managed within UCITS rules, and does not dominate the risk profile. There is no significant leverage, no embedded derivatives, and no complex or opaque index. The structure, risks, and payoffs are straightforward and can be understood by retail investors with basic knowledge. Under MiFID II, all UCITS are automatically non-complex unless they are structured UCITS (which provide algorithm-based payoffs or similar complex features)u2014this ETF does not meet that exception[1]. The limited and ancillary use of derivatives and securities lending does not, in this case, override the UCITS presumption of non-complexity, as the risks introduced are not central to the strategy and are well-disclosed[1]. The ETFu2019s risk profile (category 6) reflects market volatility, not structural complexity. Therefore, despite some derivative exposure, the ETF remains non-complex under MiFID II."
}