{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Active management, use of derivatives for risk management, investment in other funds (including UCITS ETFs), securities lending, ESG screening, quantitative models, discretionary asset allocation, counterparty risk, credit risk, liquidity risk",
    "classification": "complex",
    "supporting_data": "The iShares Growth Portfolio UCITS ETF is actively managed without reference to a benchmark, giving the investment manager broad discretion to select investments, including other UCITS ETFs and UCITS-eligible exchange-traded commodities. The fund may use financial derivative instruments to reduce risk, generate additional income, and reduce costs. It may also engage in securities lending. The fundu2019s risk profile is rated 5/7, reflecting exposure to equities, fixed income, commodities, and associated risks such as counterparty, credit, and liquidity risk. The use of derivatives, even for risk management, and the active, discretionary management approach introduce complexity beyond the standard UCITS ETF structure. The fundu2019s reliance on quantitative models, ESG screening, and discretionary asset allocation further increases the complexity of understanding its risk-return profile for the average retail investor. These features make the fundu2019s structure, risks, and potential payoffs more difficult for a retail investor with basic knowledge to understand, thus failing the 'ease of understanding' criterion under MiFID II Article 57. Therefore, despite being a UCITS ETF, this fund is classified as complex due to its active management, derivative use, and layered investment strategy."
}