{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The asset is a UCITS ETF, which under MiFID II is generally presumed non-complex due to strict regulatory requirements ensuring diversification, liquidity, and transparency. The ETF described is actively managed but predominantly invests in other UCITS funds and UCITS ETFs, which are themselves non-complex. The Fund uses derivatives only for risk reduction, currency hedging, and efficient portfolio management, not as an integral part of the investment objective or replication method. There is no indication of synthetic replication or embedded derivatives such as swaps or structured products. Securities lending is used but managed within UCITS rules and does not dominate the risk profile. There is no significant leverage beyond UCITS limits. The replication method is physical, investing in underlying securities or funds tracking indices with ESG criteria, which are transparent and straightforward. The risk profile is moderate but reflects market volatility rather than structural complexity. The Fund's structure and risks are understandable by retail investors with basic knowledge. According to MiFID II Article 254 and Delegated Regulation EU 2017/565 Article 57, and ESMA guidelines, this ETF meets all criteria for non-complex classification. Therefore, no appropriateness test or comprehension alert is required for non-advised sales."
}