{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "None",
    "classification": "non-complex",
    "supporting_data": "The ETF is a UCITS-compliant, physically replicating fund tracking a transparent equity index (MSCI EMU Climate Paris Aligned Benchmark Select Index). It primarily invests in the underlying securities of the index, with no evidence of synthetic replication, embedded derivatives, or significant use of swaps. Derivative use, if any, is limited to efficient portfolio management (EPM) and is not central to the investment strategy. There is no indication of leverage beyond UCITS limits, inverse strategies, or complex features such as contingent convertible bonds, structured notes, or opaque indices. The fund engages in securities lending, but this is a secondary activity, well-managed within UCITS rules, and does not dominate the risk profile. The index is transparent and the fundu2019s structure, risks, and objectives are straightforward and easily understood by retail investors with basic knowledge. All these factors support a non-complex classification under MiFID II Article 25(4) and Delegated Regulation Article 57, consistent with industry practice and regulatory guidance for standard UCITS equity ETFs[1]."
}